Corrective Action Report and Conditional Closure Request · Corrective Action Report and...

Corrective Action Report and Conditional Closure Request Municipal Garage Demolition and Contaminated Soil Removal NOAA Site 20/TPA Site 9e St. Paul Island, Alaska April 8, 2008

Prepared By:

National Oceanic and Atmospheric Administration National Ocean Service Office of Response and Restoration 7600 Sand Point Way NE Seattle, Washington 98115

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Corrective Action Report and Conditional Closure Request—Municipal Garage Demolition and Contaminated Soil Removal, NOAA Site 20/TPA Site 9e

Contents

EXECUTIVE SUMMARY .....................................................................................................................................ES-1 1.0 INTRODUCTION.............................................................................................................................................. 1-1 2.0 SITE DESCRIPTION......................................................................................................................................... 2-1

2.1 SITE BACKGROUND................................................................................................................. 2-1 2.2 SITE GEOLOGY.......................................................................................................................... 2-1 2.3 SITE HYDROGEOLOGY............................................................................................................ 2-2 2.4 PREVIOUS INVESTIGATIONS AND CORRECTIVE ACTIONS ........................................... 2-3

3.0 REMOVAL OBJECTIVES AND APPROACH......................................................................................... 3-1 4.0 FIELD ACTIVITIES.......................................................................................................................................... 4-1

4.1 CONTRACTORS AND EQUIPMENT........................................................................................ 4-1 4.2 LEAD CONTAMINATED SOIL INVESTIGATION ................................................................. 4-2

4.2.1 FIELD-PORTABLE X-RAY FLUORESCENCE SCREENING SAMPLES................ 4-3 4.2.2 FIXED-LABORATORY SAMPLES............................................................................. 4-3 4.3 BUILDING DEMOLITION ......................................................................................................... 4-4 4.4 EXCAVATION ACTIVITIES...................................................................................................... 4-4 4.5 SOIL DISPOSAL.......................................................................................................................... 4-5 4.6 BACKFILLING AND SITE RESTORATION ............................................................................ 4-6 4.7 INVESTIGATION-DERIVED WASTE MANAGEMENT......................................................... 4-6 4.8 SITE SURVEYING ...................................................................................................................... 4-7

5.0 FIELD SCREENING AND ANALYTICAL SAMPLING ................................................................................ 5-1 5.1 SCREENING SAMPLES ............................................................................................................. 5-1

5.1.1 PID SCREENING SAMPLES FOR PETROLEUM CONTAMINATION ................... 5-1 5.1.2 THIN-LAYER CHROMATOGRAPHY SCREENING SAMPLES FOR PETROLEUM CONTAMINATION..................................................................................................................... 5-2 5.1.3 X-RAY FLUORESCENCE SCREENING SAMPLES FOR LEAD CONTAMINATION..................................................................................................................... 5-2

5.2 CONFIRMATION SAMPLES ..................................................................................................... 5-3 5.3 WASTE CHARACTERIZATION SAMPLES............................................................................. 5-4 5.4 BACKFILL CHARACTERIZATION SAMPLES....................................................................... 5-4

6.0 ANALYTICAL RESULTS ................................................................................................................................ 6-1 6.1 CONFIRMATION SAMPLES ..................................................................................................... 6-1 6.2 CHARACTERIZATION SAMPLES ........................................................................................... 6-2 6.3 BACKFILL CHARACTERIZATION SAMPLES....................................................................... 6-3

7.0 QUALITY ASSURANCE AND QUALITY CONTROL.................................................................................. 7-1 8.0 CONCEPTUAL SITE MODEL ......................................................................................................................... 8-1

8.1 HISTORICAL SOURCES OF CONTAMINATION ................................................................... 8-1 8.2 RELEASE MECHANISMS.......................................................................................................... 8-1 8.3 IMPACTED MEDIA .................................................................................................................... 8-1 8.4 MIGRATION PATHWAYS......................................................................................................... 8-1 8.5 EXPOSURE ROUTES ................................................................................................................. 8-2 8.6 POTENTIAL RECEPTORS ......................................................................................................... 8-2 8.7 CUMULATIVE RISK ASSESSMENT........................................................................................ 8-2 8.8 MONITORING WELL NETWORK............................................................................................ 8-3

9.0 CONCLUSIONS AND RECOMMENDATIONS ............................................................................................. 9-1 9.1 CONCLUSIONS........................................................................................................................... 9-1 9.2 RECOMMENDATION ................................................................................................................ 9-1

10.0 REFERENCES ................................................................................................................................................10-1

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TABLES

Table 1 LABORATORY ANALYTICAL RESULTS FROM LEAD CONTAMINATED SOIL INVESTIGATION Municipal Garage Demolition St. Paul Island, Alaska

Table 2 SITE-SPECIFIC CLEANUP LEVELS FOR SOIL UNDER THE 10X RULE

Municipal Garage Demolition St. Paul Island, Alaska Table 3 TCLP RESULTS FOR SIDING AND INTERIOR PLYWOOD TREATED WITH

ECOBOND ST. PAUL MUNICIPAL GARAGE Table 4 ANALYTICAL DATA SUMMARY – CONFIRMATION SAMPLE RESULTS

Municipal Garage Demolition St. Paul Island, Alaska Table 5 ANALYTICAL DATA SUMMARY – CHARACTERIZATION SAMPLE

RESULTS Municipal Garage Demolition St. Paul Island, Alaska Table 6 ANALYTICAL DATA SUMMARY – BACKFILL CHARACTERIZATION

SAMPLE RESULTS Municipal Garage Demolition St. Paul Island, Alaska

FIGURES

Figure 1 St. Paul Island Vicinity Map Figure 2 Municipal Garage and Vicinity Figure 3 Areas of Previous Excavations and Lead Contamination Zone Figure 4 2003 & 2007 Soil Confirmation Samples Figure 5 National Weather Service Property Boundary Figure 6 Lead Contaminated Soil Disposal Cell in Tract 42 Figure 7 Current Monitoring Network

APPENDICES

A Photographic Documentation

B Weekly Reports

C Chemical Data Quality Assessment Summary, Laboratory Data Review Checklists, and

Laboratory Data Deliverables

D Archaeological Monitoring Report

E ADEC Approval Letter for Conditional Closure

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ACRONYMS AND ABBREVIATIONS

AAC Alaska Administrative Code ADEC Alaska Department of Environmental Conservation bgs below ground surface BSE Bering Sea Eccotech, Inc. BTEX benzene, toluene, ethylbenzene, and total xylenes CAP corrective action plan CAR corrective action report CESI Columbia Environmental Sciences, Inc. cm centimeter COC chain-of-custody CSM conceptual site model CY cubic yard DRO diesel-range organics EPA U.S. Environmental Protection Agency F&BI Friedman and Bruya Inc. FPXRF field portable x-ray fluorescence instrument ft feet GIS geographic information system GPS global positioning system GRO gasoline-range organics ICP/MS inductively coupled plasma/ mass spectrometry IDW investigation-derived waste LCS laboratory control samples mg/kg milligrams per kilogram MS/MSD matrix spike/matrix spike duplicate LCG Larson Consulting Group NOAA National Oceanic and Atmospheric Administration PAH polynuclear aromatic hydrocarbon PCS petroleum contaminated soil PID photo ionization detector PQL practical quantitation limit QA/QC quality assurance and quality control QAP quality assurance plan RPD relative percent difference RRO residual-range organics SGS SGS Environmental Services, Inc. of Anchorage, Alaska TLC thin-layer chromatography TPA Two-Party Agreement VOCs volatile organic compounds


EXECUTIVE SUMMARY

The U.S. Department of Commerce, National Oceanic and Atmospheric Administration (NOAA),

through its Office of Response and Restoration, Pribilof Project Office (PPO) is responsible for site

characterization and restoration activities on St. Paul Island, Alaska (Figure 1). The PPO conducts these

activities at several sites on the Pribilof Islands according to the Two Party Agreement (TPA) between

NOAA and the State of Alaska. This corrective action report details corrective actions conducted at the

Municipal Garage Site (NOAA Site 20/TPA Site 9e), including the adjacent former Connector Building

footprint, on St. Paul Island. This report was prepared by NOAA.

The Municipal Garage was located at the base of Village Hill, just north of the Machine Shop (Figure 2).

The building has been the location of various storage and equipment maintenance operations dating back

to the 1930s. The Municipal Garage (also referred to as the Equipment Shed and Elephant Hut) was most

recently used by NOAA for storage of heavy equipment, construction supplies, and miscellaneous items.

The concrete foundation of the former Connector Building abutted the Municipal Garage on the south

end, connecting it to the Machine Shop building.

Gasoline above ground storage tanks (ASTs) were once located on the southwest side of the Municipal

Garage, while diesel underground storage tanks (USTs) were previously located on the northwest side of

the building. Pipelines transferred diesel fuel from a Diesel Tank Farm (NOAA Site 30/TPA Site 11)

atop Village Hill to the diesel USTs. Gasoline was gravity fed to the ASTs from a former Gasoline Tank

Farm (NOAA Site 29/TPA Site 10) located on the north slope of Village Hill. There were two floor

drains inside the Municipal Garage and a small sump was located along the exterior of the south wall of

the Municipal Garage, inside the former Connector Building. A former gasoline service station was

located to the east of the Municipal Garage.

Accidental releases of diesel fuel and gasoline previously stored and/or transferred by pipelines to, or near

to, the site led to environmental contamination. Also, wastes may have been spilled or dumped into the

floor drains and sump. Investigations at the site indicated the presence of diesel-range and gasoline range

organic compounds in soil at concentrations above site specific cleanup levels. Since the Municipal

Garage had become structurally compromised due to partially rotted structural members, NOAA agreed

to demolish the structure. With the structure demolished, it was then necessary for NOAA to remove the

petroleum contaminated soil (PCS) known to exist underneath.

NOAA also discovered a six foot wide strip of soil along the north wall of the building where lead

contamination in soil exceeded the State of Alaska industrial area cleanup level for soil of 1,000 mg/kg

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total lead. This contamination was thought to have resulted from lead paint peeling off the building’s

exterior siding.

NOAA selected Bering Sea Eccotech Inc. (BSE) to implement the corrective action for the demolition of

the building and removal of PCS and lead contaminated soil at the site. NOAA’s site cleanup levels for

soil were based on ADEC Method Two, or alternative cleanup levels established under application of

ADEC’s 10x Rule where approved by ADEC. The Municipal Garage was demolished and the building

demolition debris placed in the City of St. Paul municipal landfill. During the corrective action, BSE

removed approximately 2,014 cubic yards (CY) of PCS from the site and transported it to NOAA’s

ADEC-approved landspreading area at the National Weather Service property on the island. BSE also

removed approximately 18 CY of lead contaminated soil and transported it to a disposal trench in

NOAA’s Tract 42 Landfill Cell C, covering it with at least two feet of landfill cap soil. BSE backfilled

the PCS and lead contaminated soil excavations to the original grade using clean fill material.

After completing removal of PCS at the Municipal Garage Site, confirmation samples collected from the

excavation bottom indicated concentrations of GRO and DRO and some BTEX constituents that

exceeded the site specific cleanup levels along the sides of the excavation. However, more PCS could not

be removed because this remaining contaminated soil was at the depth of groundwater (14 feet below

ground surface) or extended into areas with buried utilities that NOAA is not required to disturb. After

completing removal of lead contaminated soil, a confirmation sample collected from the excavation

bottom indicated no soil remained with lead contamination greater than the site cleanup level.

As a result of this cleanup action, all required contamination has been removed and no exposure routes

remain for human receptors or the environment. NOAA is therefore requesting in this Corrective Action

Report/Conditional Closure Request that ADEC agree further remedial action from NOAA is no longer

required at the Municipal Garage Site since the primary sources of contamination have been removed and

analytical data indicate that PCS and lead contaminated soil has been excavated to the maximum extent

practicable.


1.0 INTRODUCTION

The U.S. Department of Commerce, National Oceanic and Atmospheric Administration (NOAA),

through its Office of Response and Restoration, Pribilof Project Office is responsible for site

characterization and restoration on St. Paul Island, Alaska. St. Paul Island is located north of the

Aleutian Islands chain in the Bering Sea, approximately 800 miles west-southwest of Anchorage,

Alaska (Figure 1).

Public Law 104-91 of 1996 and Public Law 106-562 of 2000 provide the mandate for these activities. A

Two-Party Agreement (TPA), signed in 1996 by NOAA and the State of Alaska, provides the framework

for corrective action on St. Paul Island (NOAA 1996). The State of Alaska provides TPA oversight

through the Alaska Department of Environmental Conservation (ADEC). Under the TPA, NOAA is

required to comply with State of Alaska regulations in effect in 1991 (ADEC 1991); however, with

ADEC agreement, NOAA has chosen to follow more current regulations whenever possible.

This corrective action report/condition closure request (CAR/CCR) documents the 2007 corrective action

work performed at the St. Paul Island Municipal Garage site (“site”), designated by NOAA as NOAA Site

20, and also known as TPA Site 9e. The Municipal Garage was located at the base of Village Hill, just

north of the Machine Shop (Figure 2). During this corrective action, the Municipal Garage was

demolished and petroleum or lead contaminated soil was removed from the site, followed by backfilling

with clean soil. Except as noted in this CAR, field activities for this work were carried out in accordance

with the following documents:

• Corrective Action Plan (CAP) Addendum for the Removal of Lead and Petroleum Contaminated Soil at the Municipal Garage (NOAA Site 20, TPA Site 9e) St. Paul Island, Alaska. (NOAA 2006b)

• Master quality assurance plan (QAP) (NOAA 2006a)

• NOAA’s Master Investigation Derived Waste Plan (NOAA 2003b)

• Master health and safety plan (NOAA 2004a)

NOAA performed this corrective action to address environmental impacts resulting from past operations

conducted in and around the Municipal Garage. The ADEC does not require that existing buildings be

demolished to remediate environmental contamination underneath them. While the Municipal Garage

building was still usable, some of its wooden roof trusses were structurally compromised by rot and

NOAA determined that it should be demolished prior to a planned property transfer because it could be a

potential safety hazard in the future. Demolition of the structure was complicated by the fact that the

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entire structure was painted with lead based paint, preventing reuse or burning of wood parts. NOAA

collected representative samples of various parts of the building prior to demolition and analyzed them

using the Toxicity Characteristic Leaching Procedure (TCLP), EPA Method 1311 (40 CFR 261.23). The

results showed that the exterior siding exceeded allowable limits for lead leachability and would have to

be considered a Resource Conservation and Recovery Act (RCRA) hazardous waste if removed without

treatment. NOAA also found that a small area of soil along the north wall of the building exceeded the

ADEC industrial cleanup standard for lead of 1,000 milligrams per kilogram (mg/kg), although this soil

did not fail the TCLP and therefore did not require handling as a hazardous waste upon removal. Cleanup

of the known petroleum contaminated soil (PCS) underneath the building was required by State of Alaska

Regulations if the building were to be removed. Therefore, the objectives of the corrective action were as

follows:

• Treat the exterior siding of the building prior to demolition with a commercial phosphate coating that would prevent leaching of the lead paint and render it non-RCRA hazardous and therefore able to be disposed by placing it in the City of St. Paul’s municipal solid waste landfill.

• Demolish the Municipal Garage building and dispose of the wood and concrete debris in the City of St. Paul Landfill.

• Remove PCS from under the building and dispose it by land spreading it on the island at the National Weather Service land spread area.

• Remove the lead contaminated soil along the north side of the building and dispose it by burial in the NOAA Tract 42 Cell C landfill.

• Conduct all soil excavation under the oversight of an archaeologist to ensure documentation and preservation of any archaeologically significant artifacts that may be uncovered.

• Collect lead soil characterization and waste characterization and designation samples for analysis using a field-portable x-ray fluorescence meter (FPXRF), and verify FPXRF results by fixed laboratory analysis.

• Collect field petroleum hydrocarbon screening samples for analysis by thin-layer chromatography (TLC) and photoionization detector (PID).

• Collect confirmation samples from the excavation boundary for fixed laboratory analyses.

• Collect samples to characterize PCS removed from the excavation.

• Restore the site to grade with clean fill.

• Incorporate site features and sampling locations into a geographic information system (GIS) database and map project.

• Report CAP activities and results to ADEC for acknowledgement of clean closure.


2.0 SITE DESCRIPTION

The following subsections provide a description of the site background, site geology, site hydrogeology,

and previous investigations for the Municipal Garage Site.

2.1 SITE BACKGROUND

The Municipal Garage was located at the base of Village Hill, just north of the Machine Shop (Figure 2).

The building has been the location of various storage and maintenance operations dating back to the

1930s. The Municipal Garage (also referred to as the Equipment Shed and Elephant Hut) was most

recently used by NOAA for storage of heavy equipment, construction supplies, and miscellaneous items.

The concrete foundation of the former Connector Building lay between the Municipal Garage site and

Machine Shop building (Figure 2).

Gasoline above ground storage tanks (ASTs) were once located on the southwest side of the Municipal

Garage, while diesel underground storage tanks (USTs) were previously located on the northwest side of

the building (Hart Crowser 1997). Pipelines transferred diesel fuel from a Diesel Tank Farm (NOAA Site

30/TPA Site 11) atop Village Hill to the diesel USTs. Gasoline was gravity fed to the ASTs from a

former Gasoline Tank Farm (NOAA Site 29/TPA Site 10) located on the north slope of Village Hill.

Petroleum contaminated soil (PCS) had been discovered and subsequently removed from the west, north,

and east sides of the building (Figure 3) during earlier NOAA corrective actions as discussed below.

NOAA sampling had revealed that some of the soil underneath the Municipal Garage building was also

contaminated with petroleum, but since the building was still in use and had not been slated for

demolition, this contamination was not removed at that time.

2.2 SITE GEOLOGY

St. Paul Island was formed as a result of volcanic eruptions of basaltic lavas onto the southern edge of the

Bering Sea Shelf. The island has never been glaciated, and many cinder cones with steep slopes and

sharp crater rims are present on the island. The island soil is characterized primarily as volcanic deposits

consisting of scoria of varying sizes (pebbles to cobbles) and colors (lenses of gray, red, and black) with

fractured basalt occurring at depth (Barth 1956).

Soils in the vicinity of the Municipal Garage generally consist of fill material including sand, scoria, and

gravel from the surface to a depth of 2 to 12 feet below ground surface (bgs). This fill material is

underlain by approximately 3 to 14 feet of sand. Bedrock in this area consists of basalt (NOAA 2003c).

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2.3 SITE HYDROGEOLOGY

Groundwater in the vicinity of the Municipal Garage is present at approximately 4 feet above mean sea

level, which is about 14 feet bgs. Groundwater likely flows to the north toward Village Cove (NOAA

2003c). Currently, groundwater in this area is not used for drinking water, and it is not expected that it

will ever be used for drinking water. NOAA has elected to proceed with corrective actions at the

Municipal Garage and other sites within Tract 46 under the guidelines afforded by 18 AAC 75.345(b)(2)

and 18 AAC 75.350 (ADEC 2000a), commonly referred to as the Ten Times Rule (10x rule) as described

below.

NOAA performed a Groundwater Use and Classification study of St. Paul Village in 2002 Based upon

analyses of existing data, groundwater beneath the City of St. Paul is considered brackish and is therefore

not potable (Mitretek 2002, ADEC 2002). NOAA demonstrated the water is not drinkable regardless of

past petroleum releases that had resulted in groundwater exceeding ADEC Table C cleanup levels for

GRO, DRO, benzene, and toluene found in the immediate vicinity of the Municipal Garage. NOAA

requested of ADEC to utilize alternative groundwater and soil cleanup criteria allowed under (18 Alaska

Administrative Code [AAC] 75.345). If ADEC concurred the alternative would allow groundwater and

soil cleanup criteria to increase to ten times the Table C and Method Two (18 AAC 75.341) cleanup

levels for those compounds listed above. ADEC conditionally approved NOAA’s Groundwater Use and

Classification Study’s request to utilize alternative cleanup standards based on groundwater cleanup

levels and soil (protection of groundwater) cleanup levels set at 10x the Method Two and Table C cleanup

levels for those compounds listed above (ADEC 2002).ADEC’s condition required NOAA to satisfy

appropriate institutional controls as required under 18 AAC 75.350. NOAA applied to Alaska Department

of Natural Resources (ADRN) for a Critical Water Management Area (CWMA) determination under 11

AAC 93.500 - 11 AAC 93.530 (ADNR 2006), which would satisfy ADEC’s institutional control

requirement. Following numerous regulatory procedures, ADNR determined a CWMA was appropriate

for the areas with groundwater contamination in the old village. The CWMA determination allowed

NOAA to apply the alternative cleanup levels under the Ten Times Rule (ADEC 2002).

ADEC conditionally approved NOAA’s Groundwater Use and Classification Study’s request to utilize

alternative cleanup standards based on groundwater cleanup levels and soil (protection of groundwater)

cleanup levels set at 10x the Method Two and Table C cleanup levels for those compounds listed above

(ADEC 2002). Additionally, the 1996 TPA provided NOAA to clean up contaminated media on the

Pribilof Islands consistent with ADEC regulations at that time. The benzene cleanup level for soil in 1996

was based on the 0.5 mg/kg level established in ADEC 1991 promulgated regulations. As a result, NOAA

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can use 0.5 mg/kg as its benzene cleanup level. As a result, NOAA applied the 0.5 mg/kg as its benzene

cleanup level instead of 0.2 mg/kg under the Ten Times Rule or 0.02 mg/kg under ADEC Method Two.

NOAA also received approval from the State of Alaska to designate most of Tract 46 and some adjacent

areas (including the Municipal Garage site) as a Critical Water Management Area (CWMA) under 11

AAC 93.500- 11 AAC 93.530 (ADNR 2006). This designation is required in order to implement the 10x

rule.

2.4 PREVIOUS INVESTIGATIONS AND CORRECTIVE ACTIONS

During 1995, Hart Crowser, Inc. conducted an expanded site inspection that included the collection of soil

samples from the area of the Municipal Garage. Analytical data for soil samples collected during this

investigation indicated the presence of arctic diesel at concentrations up to 5,900 mg/kg at a depth of 10

feet bgs. Arctic diesel consists of diesel fuel mixed with gasoline-range hydrocarbons to prevent the

mixture from freezing (NOAA 2003c, 2003d).

During 1997, the ASTs and most of the USTs along the west side of the Municipal Garage were removed

by Aleutian Enterprises. In 2000, a UST at the southeast corner of the Municipal Garage was removed by

Columbia Environmental Sciences, Inc. (CESI) during site characterization activities (NOAA 2003b,

2003d).

During 2000, CESI also conducted additional sampling at the Municipal Garage (CESI 2001). Analytical

data for soil samples collected during this investigation indicated the presence of diesel-range organic

compounds (DRO) up to 13,000 mg/kg, gasoline-range organic compounds (GRO) up to 470 mg/kg,

toluene up to 20 mg/kg, and ethylbenzene up to 12 mg/kg (NOAA 2003b, 2003d).

Groundwater samples were collected from monitoring wells at and near the Municipal Garage in 2000 by

CESI and in 2001 by IT Alaska Corporation. Analytical data for these samples indicated the presence of

DRO, GRO, residual-range organic compounds (RRO), benzene, and toluene at concentrations exceeding

regulatory limits established by ADEC (NOAA 2003b, 2003d).

A corrective action was conducted from August 4, 2003, through September 4, 2003 to remove PCS

along the west and north sides of the Municipal Garage (Tetra Tech 2004). PCS site cleanup levels used

were those developed by NOAA for soil under the 10x rule as described in Section 2.3 above, and as

provided in section 3.0 below. A total of 2,805 cubic yards of PCS was excavated. PCS was excavated all

along the length of the western wall, all the way to the bedrock, and as close to the building as possible

(Figure 3). Confirmation samples at 10 to 15 feet bgs showed that DRO contaminated soil above the site

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cleanup level of 2,500 mg/kg continued underneath the building along the western wall. GRO

contamination exceeded the 300 mg/kg ADEC Method Two cleanup level, but GRO did not exceed the

site cleanup level of 1,400 mg/kg under the 10x rule. PCS was also excavated at the north end of the

Municipal Garage, though the extent of the excavation was restricted by the presence of a monitoring

well, electrical transformers, and the building itself. Confirmation samples inside the excavation at the

north end of the building at a depth of 10 feet bgs indicated no contamination above the site cleanup

levels or the ADEC Method Two cleanup levels, except at the north east and north west corners of the

building where DRO contamination still exceeded the site cleanup level of 2,500 mg/kg, but could not be

removed without damaging the building or adjacent utilities (NOAA 2004c).

NOAA also conducted a removal action at the Cascade Building (TPA Site 9f) in 2003, (NOAA 2005a),

adjacent to the Municipal Garage on the south east side. A total of 3,510 cubic yards of PCS were

excavated from the main part of the Cascade building site, which extended along the east foundation wall

of the Municipal Garage (Figure 3). The soil removed exceeded site cleanup levels for both DRO and

GRO. Except for two confirmation sample location near the northeast corner and center of the Municipal

Garage (Figure 4), it did not appear that the petroleum contamination continued underneath the building,

though it was not possible to excavate soil all the way to the water table along the foundation because of

risk to compromising the structure and a buried electrical line and a water main (Figure 3). Confirmation

samples at 8 to 11 feet bgs showed that the soil along the eastern wall of the Municipal garage did not

exceed either the Method Two cleanup levels or the site cleanup levels under the 10x rule, except for

GRO or DRO at two samples near the northeast corner and center of the Municipal Garage (NOAA

2005a).

NOAA collected additional characterization samples underneath the Municipal Garage by drilling

through the concrete floor in the fall of 2003. These samples showed that there were areas under the

building where the soil exceeded the site cleanup level for DRO, and the Method Two cleanup level for

GRO (NOAA 2004c).


3.0 REMOVAL OBJECTIVES AND APPROACH

The corrective action’s lead soil removal objective at this site involved the removal of all soil located

between the building’s perimeter and six (6) feet horizontally away from the perimeter, herein referred to

as the “Potential Lead-Contaminated Soil Area” (Figure 3), that exceeded the commercial and industrial

land use cleanup level of 1,000 mg/kg total lead listed in note 11 to Tables B1 and B2 of 18 AAC 75.341

(ADEC 2005). (NOTE: The CAP Addendum [NOAA 2006b] erroneously stated in Section 4.0 that the

lead contaminated zone was that “between the building’s perimeter and 10 feet horizontally away from

the perimeter”. This was a typographic error and should have said “6 feet horizontally away from the

perimeter”. Later in Section 5.1 the CAP Addendum made it clear that soil will only be characterized “6

feet horizontally from the building”. Also, in past lead contaminated soil corrective actions at the St. Paul

Teacher Houses and Duplex, NOAA only removed lead contaminated soil within 6 feet of those

structures [NOAA 2007]). The objective for the vertical extent of lead contaminated soil removal was

from ground surface to a depth of 2 feet bgs. Lead-contaminated soil exceeding the commercial and

industrial cleanup level is assumed to lack a complete risk pathway if covered by a minimum of two feet

of clean soil, which would occur if lead soil at and deeper than two feet bgs is backfilled to grade with

clean soil.

The PCS removal objective for this site involved the removal of all PCS beneath the footprint of the

demolished building (including its concrete footings and floor), that exceeded the site-specific cleanup

levels for GRO, DRO, benzene, toluene, ethylbenzene, and total xylenes (BTEX), and select polynuclear

aromatic hydrocarbons (PAHs). PCS cleanup levels for the site are detailed in the corrective action report

detailing the 2003 PCS removal activities (Tetra Tech 2004), and are based on applying the 10x (Ten

Times) rule as described in section 2.3 above. These levels are listed in Table 3-1. One should note that

contaminated soil represented by 2003 confirmation samples along the eastern edge of the building

footprint, and one near the northeast corner of the building footprint, exceed the site specific cleanup

levels (Figure 4). This soil was not excavated in 2003 due to its proximity to the building. NOAA’s

objective was to remove and temporarily stockpile the clean backfill that had been placed over these 2003

confirmation sample locations, then resume excavation of this PCS even though a portion of it may

extend outside the building footprint.

NOAA expected that the extent of PCS contamination planned to be removed at this site would be limited

by sidewall sloping requirements to prevent damaging adjacent utilities or structures including the

electrical transformer and monitoring well to the north, the former Connector Building’s concrete

foundation to the south, and the electrical supply line along the east wall (Figure 3). Also, NOAA did not

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plan the excavation to extend deeper than 15 feet bgs or to groundwater due to impracticability associated

with deep excavating and saturated soil excavation. Groundwater at this site was anticipated at

approximately 14 feet bgs.

Under the 10x rule NOAA may elect to remove PCS to a cleanup level ten times higher than the Method

Two cleanup levels for any chemical constituent found in the groundwater at levels that exceed the

groundwater cleanup level for that constituent. However, NOAA attempted to clean up soils to the

Method Two cleanup level where possible. For example, under the 10x rule the site-specific cleanup level

for DRO is 2,500 mg/kg, while the Method Two cleanup level is only 250 mg/kg.

Site-specific cleanup levels are summarized in Table 3-1. A detailed discussion on the development of

the site-specific cleanup levels for petroleum compounds can be found in the Final CAP for the 2003

corrective action along the west side of the building (NOAA 2003c).


4.0 FIELD ACTIVITIES

The following subsections summarize the equipment used and the activities performed during this

corrective action. Appendix A provides photographic documentation of the corrective action. Appendix

B provides copies of the daily reports as well as logbook notes generated during the corrective action.

4.1 CONTRACTORS AND EQUIPMENT

Bering Sea Eccotech (BSE) provided overall site management via its subcontractor Larsen Consulting

Group (LCG), including the direction of excavation and hauling activities, engineering services, and

preparation of weekly reports. The collection of screening, characterization, and confirmation samples

during implementation of the corrective action was performed by Tutka Services LLC (Tutka). BSE

provided most of the equipment used during the corrective action, but NOAA furnished some

government-owned equipment. BSE/LCG conducted health and safety meetings before the

commencement of each day’s activities. Tutka performed PID analyses of screening samples. NOAA

representatives performed TLC and FPXRF analyses of screening samples and provided survey support

using real-time kinematic GPS techniques and equipment. BSE subcontracted laboratory analytical

services to SGS Environmental Services Inc. of Anchorage, AK (SGS).

Heavy equipment used on site during field activities included the following:

• Hitachi EX150 excavator (BSE)

• Hitachi ZX200LC Excavator (BSE)

• 5-10 CY dump trucks (BSE and NOAA)

• Volvo L-70 Front End Loader (BSE)

• CAT 966 Front End Loader (BSE)

• Flat Bed Truck (BSE)

• Telescoping Rough Terrain Fork Lift (BSE)

• Trimble Total Station R8 GPS (NOAA)

• FPXRF instrument

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4.2 LEAD CONTAMINATED SOIL INVESTIGATION

During the summer of 2007 NOAA conducted additional soil sampling for lead contamination around the

perimeter of the building in a zone starting at the outer wall to 6 feet away from the wall. Samples were

collected on June 24 and June 26 from ground surface to a depth of either 1 or 2 feet as shown in Figure

3. NOAA sampled this area because of the knowledge that the exterior of the building was painted with

peeling LBP, and the peeling paint may have contaminated surface soil near the exterior wall of the

building. NOAA collected soil samples at either two or four different depth intervals at each of the

fourteen (1) locations shown on Figure 3 using a hand driven core sampler as follows:

• West side of building – 2 samples per boring at 0.0 to 0.5 foot, and at 0.5 foot to 1.0 foot. This soil was known to be clean fill placed along the wall after the 2003 Municipal Garage corrective action (NOAA 2004c). Lead contamination from recent peeling paint was expected to only have the potential to affect the surface soil.

• North and east sides of building – 4 samples per boring, at 0.0 to 0.5 foot, 0.5 foot to 1 foot, 1.0 foot to 1.5 feet, and 1.5 feet to 2.0 feet. All the soil along the north wall was believed undisturbed since construction of the building, noting that the building’s approach apron was concrete and thus soil beneath it was assumed uncontaminated by peeling LBP since the apron was poured prior to the first application of LBP to the building during its construction. Only some of the surface soil along the east wall may have been removed and replaced with clean fill during the 2003 remedial action at the Cascade Building corrective action (NOAA 2005a). Lead contamination from historic paint peeling along these sides could potentially have contaminated soil to the two foot removal action depth.

NOAA collected FPXRF screening and fixed-laboratory definitive data samples in accordance with the

CAP addendum (NOAA 2006b) and NOAA’s Master Quality Assurance Plan (NOAA 2006a). NOAA

collected the soil samples from a combination of hand excavated test pits and direct-push explorations,

then screened them at its Seattle, Washington office using its FPXRF (Table 1). Consistent with the CAP

addendum (NOAA 2006b), at least ten percent of the samples were then selected for off site laboratory

analysis to confirm the results of the FPXRF readings (Table 1). NOAA selected 1 or 2 samples from

each side of the building for laboratory analysis, based on which sample had the highest FPXRF reading

for lead from that side of the building.

The following subsections describe the instrumentation used and procedures followed during the

collection of FPXRF screening and fixed-laboratory site characterization samples. The FPXRF results are

discussed in Section 5. Laboratory analytical results are discussed in Section 6.0. Data quality is

discussed in Section 7.

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4.2.1 FIELD-PORTABLE X-RAY FLUORESCENCE SCREENING SAMPLES

FPXRF involves the use of x-rays from a depleted radioactive source to cause a fluorescence response

from metallic elements during the change of energy bands by electrons in the metal molecules as they

react with the x-rays. The response is measured by a sensor, then compared against standard responses

for materials with known levels of lead contamination using an on-board computer. ADEC approved the

use of the FPXRF for site characterization and excavation screening as part of NOAA’s CAP addendum

for the site (NOAA 2006b).

During site characterization, NOAA or PSI collected 50 samples into resealable plastic bags, with

approximately 250 grams of soil collected per sample. These samples were then shipped to NOAA’s

Seattle facility. NOAA homogenized the soil in each bag, and analyzed each sample with the FPXRF.

Table 1 provides a list of FPXRF ex-situ samples collected for the site investigation with lab analytical

results for those samples sent to an off site lab.

4.2.2 FIXED-LABORATORY SAMPLES

Fixed-laboratory analytical samples for lead were selected from the 50 FPXRF samples collected as

described above. Two samples were selected from the east and west sides of the building and one along

the north side, based on which had the highest lead content on that side according to the FPXRF results.

The homogenized bag was delivered to F&BI under chain-of-custody.

Fixed-laboratory total lead analyses were performed using inductively coupled plasma/ mass

spectrometry (ICP/MS), while leachable lead analyses were performed by first extracting the samples

using EPA Method SW-846 1311 (TCLP) then analyzing the leachates using an ICP/MS.

Site Characterization

NOAA sent six (6) site characterization samples collected in June 2006 for fixed-laboratory total lead

analysis to verify the accuracy of the 50 FPXRF site characterization analyses.

Confirmation Sampling

NOAA sent one confirmation sample for fixed-laboratory total lead analysis to confirm site excavation

removed all soil exceeding the ADEC industrial cleanup level at the point of compliance.

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4.3 BUILDING DEMOLITION

NOAA’s contractor BSE began work at the site on August 2, 2007. Photograph 2 shows a view of the

Municipal Garage (in center) taken in 2006 from the top of Village Hill. A portion of the Machine Shop

is visible in the lower right corner, and the space between the two buildings is occupied by the concrete

pad from the former Connector Building. BSE removed several remaining items owned by NOAA from

the building’s interior and stored or disposed of them. Next, BSE coated the lead painted exterior siding

and a small area inside the south east corner of the building with a commercial phosphate based paint

(Ecobond LBP) that was designed to bind with lead in the paint and render it less soluble (Photograph 3).

Previous samples of the paint in these two areas had failed the TCLP limit of 5.0 mg/L for lead. The

siding and the material from the interior painted walls would have required handling as a RCRA

hazardous waste if they had been removed from the building in that condition. After coating the surfaces

with Ecobond LBP, BSE then coated the same surfaces with a latex based primer, in order to better bind

any peeling paint chips to the substrate. The Ecobond did not adhere well to the exterior siding on the

south end of the building, so this was manually removed, brought inside the adjacent Machine Shop

building, then after drying the siding was recoated with Ecobond LBP and primer. BSE collected

samples from the exterior siding and the interior wall materials after coating them with the Ecobond LBP.

These were analyzed by the TCLP and found to no longer exceed 5.0 mg/L (Table 3-1), and thus would

be a non-hazardous solid waste if removed and disposed. At this point, demolition of the building

proceeded (Photograph 4), with the wooden portions being buried in the City of St. Paul landfill. The City

of St. Paul used the concrete portions (Photographs 5 and 6) being used at the landfill to extend their

containment berm, enlarging the capacity of the landfill to accept more solid waste. The only portion of

the building remaining was the concrete stem wall and footings along the north end of the building

(Photographs 7, and 8). This was left in place because of the presence of lead contaminated soil as shown

in Figure 3. NOAA was concerned that if the footings (installed 3 to 4 feet below the surface) were

removed, some of the lead contaminated surface soil could fall into the remaining void and be mixed into

the deeper soil.

4.4 EXCAVATION ACTIVITIES

In 2006, NOAA contracted an archaeologist to evaluate the Municipal Garage site and its historical

background in preparation for the PCS excavation work (Mobley 2006). The archaeologist identified a

potential for significant archaeological deposits underneath or near the Municipal Garage and Connector

Building pad, and along the north wall where soil was not already disturbed by prior remedial actions.

The archaeologist’s report provided a monitoring plan that NOAA’s excavation contractor used to plan

and conduct archaeological monitoring during the PCS excavation.

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All soil excavation activities at the Municipal Garage Site proceeded under the supervision of an

archaeologist to ensure proper conservation and management of any significant archaeological deposits

unearthed during excavation. The archaeologist monitored all excavation at the site with the authority to

halt excavation and consult with the Alaska State Historical Preservation Office upon the discovery of

significant archaeological deposits. Although the archaeologist observed many discarded artifacts from

the early 1900s beneath the site, he did not deem any to be “significant archaeological deposits”, and the

excavation proceeded without interruption. The archaeologist’s monitoring report (Pipken 2007) is

included as Appendix D.

Approximately 18 CY of lead contaminated soil was removed from a 6 foot wide, 2 foot deep strip along

the exterior of the north wall of the building (Photograph 9). Excavation of approximately 1,632 CY of

PCS (Photograph 11) from under the building footprint and along the exterior of the north wall

(Photograph 10) began on August 29 and terminated on September 7, 2007. BSE completed excavation

of all petroleum contaminated soil under the original footprint of the building, extending into the clean

backfill along the west side of the building from the 2003 excavation, and as far as could be excavated

before threatening adjacent buried utilities along the north and east sides of the building (Figure 4).

Approximately 1/3 of the area under the original footprint of the building in the southeast corner was not

contaminated and left in place. Figure 4 and Photograph 11 show the final extent of the PCS excavation

under the Municipal Garage. However, an area of heavily contaminated soil was discovered underneath

an old sump located inside the former Connector Building, just outside the former south door of the

Municipal Garage (Photograph 11). The petroleum contamination emanating from the sump extended

from the sump down to the groundwater at 14 feet bgs. It occupied an area approximately15 feet in

diameter along the exposed face (Photograph 12). NOAA proceeded with further excavation at the sump

after backfilling the Municipal Garage Site (Photograph 13). NOAA’s contractor excavated an additional

385 CY of PCS under the Connector Building Pad on October 21 and 22, 2007 (Figure 4, Photograph 14).

This brought the total volume of PCS excavated to 2,017 CY. The excavation was backfilled following

collection of confirmation samples on October 23, 2007 (Photograph 15).

4.5 SOIL DISPOSAL

During the Municipal Garage corrective action, NOAA’s contractors transported PCS directly to NOAA’s

National Weather Service landspreading area (Figure 5). The PCS was spread no more than 0.5 ft ± 3

inches deep (Figure 5). NOAA spread soils with high levels of gasoline separately at the landspreading

area. NOAA’s contractor will till the contaminated soil to promote evaporation of volatile organic

compounds (VOCs) during the spring of 2008. The landspreading area with the Municipal Garage and

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Connector Building Pad PCS will be fertilized and seeded with native grasses to promote revegetation

after the tilling is complete.

BSE transported the lead contaminated soil to the NOAA Tract 42 landfill where it was placed in a

disposal cell excavated into the capping material, atop approximately 2,000 pounds of a phosphate soil

amendment (Ecobond) design to reduce the leachability of lead (Figure 6). NOAA was not required to

use Ecobond with the lead contaminated soil, however it chose to place Ecobond in the bottom of the lead

soil disposal trench as a precaution as well as a means to dispose of its otherwise unneeded supply of

Ecobond. A small area of the Tract 42 landfill was reopened by NOAA in 2006 in order to dispose of

demolition debris from lead and asbestos abatement projects at the Municipal Garage and other NOAA

buildings on the island. These cells were recapped after materials from the Municipal Garage were

disposed in them, using the same capping material spread at a thickness of 2 feet or greater. The areas at

Tract 42 that were disturbed by the 2006 landfilling activity were revegetated in 2007, and the area

disturbed in 2007 will be revegetated in 2008.

4.6 BACKFILLING AND SITE RESTORATION

Backfilling the excavation began after a point was reached where no more soil could be excavated, or

when soil testing with FPXRF, PID and TLC screening sample analyses indicated contaminant

concentrations were below ADEC Method Two cleanup levels, and fixed laboratory confirmation

samples had been collected. Backfill operations involved transporting clean fill from an on-island scoria

pit to the site, dumping the material into the excavation, and compacting the fill material. Samples of the

backfill material were collected and sent to a fixed laboratory for analysis, which showed no petroleum,

PAHs, or lead present above State of Alaska Method Two cleanup standards for soil. Approximately

1,627.5 CY of scoria were used to backfill the Municipal Garage excavation, and another 363 CY for the

area under the former Connector Building Pad, bringing the total to 1,990.5 CY. Also, approximately 15

cubic yards of concrete from demolition of the former connector building pad was used as clean backfill.

The backfilled area was leveled to the surrounding grade.

4.7 INVESTIGATION-DERIVED WASTE MANAGEMENT

Investigation-derived waste generated during this corrective action included:

• Used nitrile sampling gloves, which were placed in trash bags and disposed as municipal solid waste.

• Plastic bags and glassware, which were emptied of soil and disposed as municipal solid waste.

• Soil not extracted during TLC screening sample analyses, which was disposed at the landspreading site.

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4-7

• Spent methylene chloride and small vials of soil extracted with methylene chloride from TLC analyses, which were containerized in glass jars, placed in lab pack containers and stored to be shipped off-island for disposal as hazardous waste in 2008.

• Silica gel plates spotted with methylene chloride during TLC analyses, which were containerized in glass jars and placed in lab pack containers, then prepared to be shipped off-island for disposal as hazardous waste in 2008.

All such wastes were disposed according to NOAA’s Master Investigation Derived Waste Plan (NOAA

2003b)

4.8 SITE SURVEYING

NOAA representatives surveyed sampling locations, benchmarks, excavation extents, and buildings using

a survey-grade Trimble Total Station® R8 differential GPS. The Trimble Total Station® R8 is a GPS and

GIS data collection and mapping system that combines a high-performance, dual-channel GPS receiver

and antenna with a local base station and real-time differential correction system to provide survey-grade

accuracy in real time. NOAA’s survey-grade GPS determines horizontal positions of soil sampling

locations and excavation boundaries to within approximately plus or minus 1 centimeter (cm), and

elevations to within approximately plus or minus 2 cm. NOAA collected survey data in latitude and

longitude referenced to the World Geodetic System 84 Datum, Universal Transverse Mercator Zone 2

coordinate system in meters. However, most confirmation samples were collected at the toe of

potentially unstable excavation sidewalls inside the excavation and it was unsafe to enter the excavation

to survey the exact location. Consequently, NOAA surveyed these samples at a point on the upper rim of

the excavation, as close to the actual sample location as deemed safe to approach. Therefore, each survey

point for these samples is displaced approximately 2 to 3 feet laterally, and up to 14 feet vertically higher

than the actual sample location.


5.0 FIELD SCREENING AND ANALYTICAL SAMPLING

During this corrective action, BSE collected screening and analytical confirmation samples in accordance

with the CAP addendum (NOAA 2006b) and 18 AAC 78 (ADEC 2003). For petroleum contamination,

NOAA performed TLC screening sample analyses, and provided the results to BSE to direct excavation

activities and identify locations for analytical confirmation samples; BSE performed PID screening

sample analyses for petroleum contamination. Based on evaluation of the TLC and PID screening sample

results, BSE selected analytical sampling locations where the greatest potential for residual contamination

existed. BSE also collected screening and laboratory confirmation samples for lead contamination in soil;

NOAA analyzed lead soil field screening samples using its FPXRF, and provided the results to BSE to

direct excavation activities and identify locations for analytical confirmation samples.

The following subsections describe the instrumentation used and procedures followed during the

collection of screening and analytical confirmation samples.

5.1 SCREENING SAMPLES

NOAA used three different technologies to screen soil samples in the field in order to facilitate rapid

decision making, as described below.

5.1.1 PID SCREENING SAMPLES FOR PETROLEUM CONTAMINATION

As excavation of contaminated soil progressed and the remaining soil was no longer obviously

contaminated with petroleum hydrocarbons as determined by visual and olfactory inspection, BSE

collected field screening samples of soil from the bottom (or sidewalls) of the excavation, as directed by

the on-site NOAA representative. BSE used a PID as a first screening method to determine whether

remaining soil was still contaminated as specified by the CAP (NOAA 2003c). The soil sample was first

warmed to approximately room temperature while sealed inside a plastic bag, and then the PID was

inserted into the bag to sample any VOC vapors that may have been released. The PID was used because

it can detect low levels of VOCs, which were expected because high levels of GRO and BTEX had been

detected in the soil underneath the Municipal Garage by previous NOAA laboratory analyzed samples. A

PID cannot distinguish between the main VOC constituents that had previously been found to exceed

ADEC cleanup standards (such as benzene) and other VOCs such as toluene, ethylbenzene, and xylenes.

Nevertheless, if VOCs were detected above background levels, the soil represented by the sample was

assumed to be contaminated above site cleanup levels and was removed. If the soil sample did not show

elevated VOC levels according to the PID reading, then a second aliquot of the sample was given to

NOAA to perform TLC analysis as described below.

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5.1.2 THIN-LAYER CHROMATOGRAPHY SCREENING SAMPLES FOR PETROLEUM CONTAMINATION

TLC is the use of solid-liquid chromatography for the semi-quantitative analysis of DRO in soil. A

specific analytical method designed by NOAA, TLC, was originally used in support of field efforts during

a crude oil spill in the State of Washington (NOAA 2006a).

The procedure involves the solvent extraction of soil screening samples in a field laboratory and

subsequent comparison of the extracts to a range of standard diesel concentrations. By using standards

that include diesel concentrations equal to, above, and below site-specific cleanup levels, the analyst

determines whether the sample contains concentrations above or below the site cleanup level; in addition,

the analyst is able to determine an approximate concentration of DRO in each sample.

TLC screening samples were collected throughout the corrective action by placing a small amount of soil

(at least 20 grams) into a clean, re-sealable plastic bag. Each sample was homogenized and kept cool

until it could be processed at the NOAA field laboratory.

5.1.3 X-RAY FLUORESCENCE SCREENING SAMPLES FOR LEAD CONTAMINATION

While none of the FPXRF readings exceeded the industrial lead cleanup level of 1,000 mg/kg total lead,

the sample with the highest FPXRF reading, SP20-CH-108-015, was the only sample to exceed 1,000

mg/kg total lead in the laboratory analysis. These samples indicated that only the soil along the north end

of the building exceeded the state of Alaska industrial cleanup level (18 AAC 75.340 Table B1) of 1,000

mg/kg lead. NOAA analyzed samples SP20-CH-108-005 and SP20-CH-108-015 (the sample with the

highest FPXRF reading for lead) by the TCLP, finding that neither exceeded the TCLP limit of 5.0 mg/L

(Table 1). Therefore, the soil along the north wall represented by these samples would not need to be

handled as a hazardous waste during excavation and disposal. Based on the characterization data, NOAA

estimated 20 CY of lead contaminated soil would require removal and disposal.

NOAA had determined that the soil 6 feet out from the concrete foundation along the north side of the

building would be excavated to a predetermined depth of 2 feet to remove lead contamination from

peeling exterior siding paint, based both on the ADEC-approved points of compliance (NOAA 2006b)

and lead soil characterization results. NOAA’s characterization results indicated lead soil contamination

exceeded the State of Alaska industrial site lead cleanup level of 1,000 mg/kg total lead extends no

greater than 1.5 ft bgs. Nonetheless, NOAA chose to remove lead soil to 2.0 ft bgs in this area to simplify

the excavation work. Once two feet of soil was excavated, NOAA used an FPXRF instrument to

5-2


determine whether soil remaining at that depth still exceeded the lead cleanup level in soil. The soil

sample was then sent for laboratory confirmation analysis.

5.2 CONFIRMATION SAMPLES

Once petroleum screening samples indicated that the remaining soil did not contain elevated lead, VOCs

or DRO from the FPXRF, PID, and TLC testing, Tutka collected a confirmation sample by placing a split

of the screening sample into appropriate containers for fixed laboratory analyses by SGS to verify

concentrations of contaminants remaining in soil in the excavation. Section 7.1.2 describes the

confirmation sampling procedures. Confirmation samples were packaged and shipped to SGS via Air

Cargo Express, to Anchorage Airport, picked up by either a courier or a BSE employee for transport to

SGS. SGS conducted the following analyses:

• Total lead by U.S. Environmental Protection Agency (EPA) SW-846 (EPA 1996) Method 6020

• BTEX by EPA Method 8021B

• GRO by ADEC Method AK101

• DRO by ADEC Method AK102

• RRO by ADEC Method AK103

• PAHs by EPA SW-846 (EPA 1996) Method 8270C, Selected Ion Monitoring

One confirmation sample and one duplicate sample were collected to verify the lead concentration of soil

that remained along the north end of the building where a strip of soil 2 feet deep by 6 feet wide was

excavated. BSE initially collected fifteen (15) petroleum contamination confirmation samples, plus two

duplicate samples during corrective action activities at the Municipal Garage Site. BSE then collected

eleven (11) additional confirmation samples after the excavation was extended under the former

connector building pad. Figure 4 illustrates the approximate sampling locations. Since most of the

samples were collected from the toe of the nearly vertical excavation side wall, at a depth of

approximately 14 feet, the surveyor could not enter the excavation to place the survey instrument directly

on the sample location due to safety considerations. Instead, a point was surveyed just adjacent the actual

sample location at the top edge of the side wall. This point was usually displaced only 2 to 3 feet

horizontally from the actual sample point.

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5-4

5.3 WASTE CHARACTERIZATION SAMPLES

BSE collected 18 characterization samples from the 2,017 CY of PCS excavated from the site. SGS

analyzed all the samples for BTEX, GRO, DRO, RRO, and some of the samples for PAHs per the

methods listed in Section 5.2. The total and TCLP sample analyses conducted during the June 2007

characterization sampling discussed in Section 4.2 above also served as waste characterization samples

for the lead contaminated soil removed from the site for disposal at the Tract 42 landfill.

5.4 BACKFILL CHARACTERIZATION SAMPLES

BSE collected three characterization samples from 1,990.5 CY of scoria obtained from the Lake Hill

scoria pit and used as backfill for the excavation at the Municipal Garage Site. Backfill characterization

samples were analyzed by SGS for BTEX, GRO, DRO, RRO, and PAHs.


6.0 ANALYTICAL RESULTS

The following subsections summarize the analytical results for samples collected during corrective action

activities at the Municipal Garage. Tables 6-1 through 6-3 provide an analytical data summary.

Appendix C includes the analytical data for soil samples collected during the corrective action.

Laboratory reporting limits for non-detected compounds were mostly below ADEC Method Two cleanup

levels except for several halogenated organic compounds in some samples (e.g., samples SP20-CS-021-

140 and SP20-CS-029-130). In several samples the practical quantitation limit (PQL) for benzene was

above the ADEC Method Two and the TPA-approved cleanup levels, coinciding with high detections of

ethylbenzene in the same sample that could indicate contaminant interference. Section 7.0 of the report

will address data usability issues associated with these issues.

6.1 CONFIRMATION SAMPLES

As shown in Table 4 and Figure 4, confirmation samples collected from the bottom of the excavation at

the Municipal Garage Site indicated concentrations of DRO and GRO and some BTEX constituents

exceeded the site cleanup levels along the four sides of the excavation. Soil with several constituents

exceeding the site cleanup level was found at the depth of the water table (about 14 feet) along the west

side.,. Petroleum constituents above the site cleanup levels remain in soils at the water table along the

north and northeast sides of the site. Further excavation was precluded because of the risk to buried

utilities. NOAA’s initial extent of excavation along the southeast wall of the Municipal garage was

extended to include soils below the concrete pad of the adjacent former Connector Building. The

additional excavation effort became necessary when high levels of petroleum contamination were found

in soils beneath a former used oil sump located along the south wall of the former Connector Building.

After removing the concrete pad another 385 CY of soil was excavated from the site. Additional

confirmation samples (Figure 4) showed that contamination had been removed down to the water table,

which was still contaminated above the site cleanup level. For example, sample SP20-CS-306-140 at 14

feet bgs still exceeded the cleanup level, while sample SP20-CS-306-100 at the same location but at only

10 feet bgs did not exceed the cleanup level. This finding suggests that the source of contamination

within the vadose zone had been removed, but petroleum products within the groundwater smear zone

migrate along the water table.

Petroleum contaminant concentrations remaining at the site varied among the analytes. Several analytes

exceeded the site cleanup levels allowed under the 10x rule determination: GRO reached a concentration

as high as 3,430 mg/kg. DRO concentrations varied from not detected to 10,900 mg/kg. Total xylenes

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was detected above its Method Two cleanup level (78 mg/kg) as high as 735 mg/kg. Since total xylenes

have never been detected above the cleanup level in groundwater at Tract 46, it is not subject to the 10X

rule alternative cleanup level of 780 mg/kg. However, the detection of total xlyene above Method Two

occurred only within the water table’s smear zone, and is not subject to removal activity. Toluene

exceeded the Method Two and the 10x rule alternative cleanup level with a reading of 123 mg/kg at a

single location. As with total xylenes this level of toluene occurred within the water table’s smear zone.

All soil contaminant concentrations as measured in post excavation confirmation samples are presented in

Table 4. Figure 4 depicts the sample locations.

In one confirmation sample (SP20-CS-401-130) benzene was detected at an estimated concentration of

.639 mg/kg, which is above the site cleanup level of 0.5 mg/kg. The PQL for this sample was 1.38

mg/kg. However, this sample is a duplicate of sample SP20-CS-308-130, which did not detect benzene at

a PQL of 1.04 mg/kg. Since the estimated benzene value was less than the PQL in both these cases, it

cannot be determined whether the samples actually did contain benzene above the cleanup level. Since

the confirmation sample and its duplicate were not homogenized prior to placing them in their sample

jars, it is reasonable that their results would vary significantly. NOAA used the higher estimated result

from the duplicate sample in mapping and discussion of contaminant levels at the site. As noted in the

discussion of data quality, the PQL for benzene was above the site cleanup level in several of the samples

coinciding with high detections of ethylbenzene. It is possible the benzene also exceeded its cleanup

level in these samples but the data can neither prove nor disprove this.

All other contaminants were either not detected (with PQLs below ADEC Method Two cleanup levels),

or were detected at concentrations below ADEC Method Two cleanup levels.

6.2 CHARACTERIZATION SAMPLES

Characterization samples collected from PCS removed from the Municipal Garage site contained several

constituents that exceeded the site cleanup levels, including DRO with concentrations that varied from not

detected to 6,860 mg/kg, GRO (as high as 1,600 mg/kg), ethylbenzene (as high as 20.6 mg/kg), and total

xylenes (as high as 231.9 mg/kg). Toluene did not exceed the alternate cleanup level, but was detected as

high as 11.4 mg/kg. Table 5 provides an analytical data summary of characterization sample results. The

characterization samples collected during the June 2007 investigation detected lead as high as 1,160

mg/kg in the area where soil was eventually removed during this corrective action. Since only 18 CY of

lead contaminated soil was removed during this corrective action, no additional characterization samples

were collected from the soil removed.

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6-3

6.3 BACKFILL CHARACTERIZATION SAMPLES

Backfill characterization samples collected from the Lake Hill scoria pit indicated concentrations of all

clean backfill-specific analytes below the ADEC Method Two cleanup levels (Table 6).



6-1


7.0 QUALITY ASSURANCE AND QUALITY CONTROL

To ensure that information obtained from field and laboratory procedures is an accurate and defensible

representation of site conditions, quality assurance and quality control (QA/QC) procedures were

implemented. NOAA followed the operational guidelines set forth in the ADEC Environmental

Laboratory Data and Quality Assurance Requirements memorandum (ADEC 2006) as well as those

stipulated in the Pribilof Islands site restoration QAP (NOAA 2006a). These documents provide detailed

QA/QC information pertaining to each quality control item discussed in this section. Appendix C

contains a Chemical Data Quality Assessment Summary and 6 copies (one for each sample delivery

group) of the ADEC-required (ADEC 2006) Laboratory Data Review Checklist completed by NOAA’s

contractor, BSE/Tutka, LLC.

Although the Chemical Data Quality Assessment Summary in Appendix C points out various instances

with the data set in which data quality objectives defined by the QAP were not met, the data are

satisfactory for decision making purposes.

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8.0 CONCEPTUAL SITE MODEL

A conceptual site model (CSM) is used to evaluate exposure pathways for human health and ecological

receptors (ADEC 2000b). The following subsections provide an evaluation for each of the elements of

the CSM for the Municipal Garage, including historical contamination sources, release mechanisms,

impacted media, migration pathways, exposure routes, potential receptors, and a cumulative risk

assessment.

8.1 HISTORICAL SOURCES OF CONTAMINATION

Historical sources of contamination (e.g., peeling LBP, a sump, two floor drains inside or adjacent to the

building, ASTs, USTs, and fuel pipelines around the outside of the building) were removed from this site.

The resulting contamination (i.e., lead contaminated soil and PCS) was mostly removed from the site

during the 2007 field season, except for petroleum contaminated soil at the depth of groundwater (14 feet

bgs) and contaminated soil near underground utilities.

8.2 RELEASE MECHANISMS

Potential release mechanisms include LBP peeling from the Municipal Garage building, wastes dumped

into the sump and the floor drains, and leaks and spills from the ASTs, USTs, and pipelines.

8.3 IMPACTED MEDIA

As a result of past releases, NOAA identified lead contaminated soil and PCS during site investigations.

During the 2003 field seasons, NOAA removed PCS from areas on 3 sides of the site to depths up to 15

feet bgs. Groundwater was consistently encountered at approximately 14 to 15 ft bgs. Contaminated soil

was left behind in these excavations because the water table was reached, or because the contamination

continued beneath the Municipal Garage, the connector building next door, or close to buried utilities. In

2007, NOAA removed the Municipal Garage and part of the pad under the former connector building,

then removed lead contaminated soil adjacent the northwest end of the building as well as PCS that had

been underneath the buildings, again reaching PCS excavation depths of 14 feet deep. Analytical data for

confirmation samples indicates that contamination remains in some areas at the interface of the

groundwater table.

8.4 MIGRATION PATHWAYS

NOAA removed all lead contaminated soil that exceeds the site cleanup level, thus no migration pathway

remains for this contaminant. NOAA removed PCS to the groundwater table (14 to 15 feet bgs). PCS

that was not removed from the groundwater table continues to be a source of contamination to

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groundwater. The majority of PCS, however, has been removed from this site, and the source volume has

been significantly reduced.

NOAA removed petroleum-contaminated surface soil, and no overland transport pathway is available to

PCS remaining at 14 to 15 feet bgs.

8.5 EXPOSURE ROUTES

Because NOAA has removed all lead contaminated soil that exceeds site cleanup levels, all exposure

routes have been eliminated for this contaminant. Because NOAA has removed nearly all PCS down to

the groundwater table, direct exposure pathways such as dermal contact with or incidental ingestion of

PCS no longer exist at this site. The depth of remaining contamination likely precludes inhalation of

source material vapors or contaminated soil particles or direct contact with this soil. However, some

contamination remains above cleanup criteria in soil at or near the water table at 13 to 14 feet bgs. The

contaminant analytes are discussed below in section 8.7. Inhalation and ingestion of contaminated

groundwater are not considered viable exposure routes because no water production wells are located in

the vicinity; therefore, exposure to contaminated groundwater is unlikely. Given the proximity of the site

to the harbor and the direction of groundwater flow, it is possible that the contaminated groundwater

could migrate to the surface water of the harbor; however, there is no indication of this occurring. NOAA

is conducting long term groundwater monitoring of wells located between the site and the harbor and will

be able to detect in any such migration if it should occur (NOAA 2005b).

8.6 POTENTIAL RECEPTORS

Potential exposure pathways have been mitigated, and indirect exposure routes are not considered viable

given existing site conditions, thus no potential receptors have been identified.

8.7 CUMULATIVE RISK ASSESSMENT

Cumulative risk is defined as the sum of risks resulting from multiple sources and pathways to which

humans are exposed. When more than one hazardous substance is present at a site or multiple exposure

pathways exist, the cleanup levels in Table B1 of 18 AAC 75.341 and Table C of 18 AAC 75.345 may

need to be adjusted downward. In accordance with the requirements outlined in 18 AAC 78.600, NOAA

must ensure that the cumulative cancer risk remaining after the completion of the corrective action does

not exceed 1 in 100,000 (1 × 10-5) and that the cumulative non-carcinogenic hazard index does not exceed

1.0. Each contaminant detected above one-tenth of the Table B1 inhalation or ingestion cleanup levels

(excluding DRO, GRO, and RRO) must be included in cumulative risk calculations (ADEC 2007) if those

contaminants are found in soil or groundwater to which there is a complete pathway. However, the only

8-2


8-3

remaining soil with levels of contamination above one-tenth of the Table B1 inhalation or ingestion

cleanup levels at the site are found within the groundwater smear zone at 13 to 14 feet bgs. Since there is

no complete exposure pathway to this soil or groundwater, there is no risk to human health, and no

cumulative risk calculation is required with respect to this soil. No soil samples collected within soil

shallower than the smear zone at the site exceeded one-tenth of the Table B1 inhalation or ingestion

cleanup levels, so no cumulative risk calculation is required for the site.

8.8 MONITORING WELL NETWORK

Monitoring wells located in the vicinity of the site include MW46-6, MW46-28, MW46-5, MW46-9,

MW46-14, MW46-10, and MW46-15 (Figure 7).



8-1


9.0 CONCLUSIONS AND RECOMMENDATIONS

The following subsections present conclusions and recommendations for the Municipal Garage on field

activities performed and analytical findings obtained from corrective action activities conducted during

the 2004 field season.

9.1 CONCLUSIONS

NOAA and its contractors removed approximately 2,017 CY of PCS and 18 CY of lead contaminated soil

from the Municipal Garage and Connector Building sites. No lead contaminated soil remains above the

site cleanup level of 1,000 mg/kg. Although confirmation sample data indicated that GRO, DRO, toluene,

ethylbenzene, and total xylenes concentrations remain above the site cleanup level in some portions of the

bottom of the excavation, further excavation was not practicable due to the presence of groundwater (18

AAC 75.325(f), 18 AAC 75.990). Because of the great depth of the remaining contamination (13 to 15

feet bgs), there is no complete exposure pathway to humans or the environment, and therefore no

unacceptable risks are present. Groundwater in the vicinity of the site is being monitored to evaluate

contaminant attenuation and to ensure that if contaminant levels increase they do not pose an

unacceptable risk to the environment.

9.2 RECOMMENDATION

Because NOAA removed the primary sources of contamination and met the objectives of the CAP

addendum, NOAA seeks a conditional closure for soil contamination at the Municipal Garage site. ADEC

can concur with this request by providing NOAA with a signed copy of the conditional closure approval

letter attached at the end of this report as Appendix E.

9-1



9-1


10.0 REFERENCES

Alaska Department of Environmental Conservation (ADEC). 1991. Interim Guidance for Non-UST Contaminated Soil Cleanup Levels. Contaminated Sites Program. July 17.

ADEC. 2000a. 18 AAC 75, Articles 3 and 9. Oil and Hazardous Substances Pollution Control Regulations. State of Alaska. Amended through October 28, 2000.

ADEC. 2000b. Risk Assessment Procedures Manual. June 8.

ADEC. 2002. Letter from Jennifer Roberts. Re: Draft Final Groundwater Use and Classification in the Vicinity of Tract 46. May 30.

ADEC. 2005. 18 AAC 75, Articles 3 and 9. Oil and Hazardous Substances Pollution Control Regulations. State of Alaska. Effective date October 16.

ADEC. 2006. Technical Memorandum -06-002. Environmental Laboratory Data and Quality Assurance Requirements. ADEC Division of Spill Prevention and Response, Contaminated Sites Program. October 9.

ADEC 2007. Public Review Draft Cumulative Risk Guidance. August 30.

Alaska Department of Natural Resources (ADNR). 2006. CWMA Commissioner’s Order and Record of Decision, St. Paul Island, Alaska. Includes cover memorandum by Gary J Prokosch and memorandum by Michael L. Mange. April 5.

Barth, T.F.W. 1956. “Geology and Petrology of the Pribilof Islands, Alaska”. U.S. Geological Survey Bulletin 1028-F.

CESI. 2001. Draft Site Characterization Report, Tract 46 and Vicinity (TPA Site 9), St. Paul Island, Alaska. Version 2.1 December 16, 2001. Columbia Environmental Sciences, Inc. Kennewick, WA.

Hart Crowser. 1997. Expanded Site Inspection, St. Paul Island, Pribilof Islands, Alaska, Volume 1. January.

Mitretek. 2002. Groundwater Use and Classification in the Vicinity of Tract 46, St. Paul Island, Pribilof Islands, Alaska. Technical Analysis and Recommendations. Prepared by Mitretek Systems, for National Oceanic and Atmospheric Administration. June 5.

Mobley, Charles M. 2006. Determinations of Effect and Monitoring Plan for Cultural Resources, National Oceanic & Atmospheric Administration Environmental Restoration Program, St. George and St. Paul Islands, Alaska.

National Oceanic and Atmospheric Administration (NOAA). 1996. Pribilof Islands Environmental Restoration Two-Party Agreement, Attorney General’s Office File No. 66-1-95-0126. January 26.

NOAA. 2003b. Master Investigation-Derived Waste Plan. Pribilof Islands Site Restoration, Saint Paul Island. May.

10-1


10-2

NOAA. 2003c. Final Corrective Action Plan for the Removal of Petroleum Contaminated Soil at the Municipal Garage/Machine Shop Site (Site 20, TPA Site 9e), St. Paul Island, Alaska. July 25.

NOAA. 2003d. Initial Draft Site Characterization Report, Tract 46 and Tract A, Two-Party Agreement Sites 9a through 9s, Pribilof Islands Environmental Restoration Project, St. Paul Island, Alaska. May 19.

NOAA. 2004a. Master Health and Safety Plan. Pribilof Islands Site Restoration Project, Saint Paul Island, Alaska. April 12.

NOAA. 2004b. Operations Work Plan, Petroleum Contaminated Soil Remediation by Landspreading, St. Paul Island, Alaska. June 23.

NOAA. 2004c. Final Corrective Action Report Site 20/TPA Site 9e – Municipal Garage/Machine Shop St. Paul Island, Alaska. October 22.

NOAA. 2005a. Final Long Term Groundwater Monitoring Plan St. Paul Island, Alaska. August 29.

NOAA. 2005b. Final Corrective Action Report Site 22/TPA Site 9f – Cascade Building St. Paul Island, Alaska. February 22.

NOAA. 2006a. Master Quality Assurance Plan. Pribilof Islands Site Restoration, Saint Paul Island, Alaska. May.

NOAA. 2006b. Corrective Action Plan Addendum for the Removal of Lead and Petroleum Contaminated Soil at the Municipal Garage (NOAA Site 20, TPA Site 9e) St. Paul Island, Alaska. April 20.

NOAA. 2007. Corrective Action Report/Conditional Closure Request, NOAA Site 60/Non-TPA-Lead contaminated Soil, St. Paul Island, Alaska. February 7.

Pipken, M. E. 2007. Archaeological Monitoring of the Excavation of the Municipal Garage and the Connector Building Sites in Saint Paul, Alaska. Walking Dog Archaeology. December.

Tetra Tech EM Inc. (TTEMI). 2004. Final Corrective Action Report, Site 20/TPA Site 9e – Municipal Garage/Machine Shop, St. Paul Island, Alaska. October 22.

U.S. Environmental Protection Agency (EPA). 1996. Test Methods for Evaluating Solid Waste. EPA/SW-846. Third Edition and Updates. December.


TABLES

TABLE 1RESULTS OF 2007 NOAA BUILDING PERIMETER INVESTIGATIN FOR LEAD IN SOIL

Municipal Garage Demolition St. Paul Island, AlaskaPage 1 of 2

Reading Error

mg/kg +/- mg/kg mg/kg mg/LSP20-CH-101-005 West (2003 clean fill) 8.22 19.07 823.00SP20-CH-101-010 West (2003 clean fill) -8.92 21.73SP20-CH-102-005 West (2003 clean fill) 1.48 18.59SP20-CH-102-010 West (2003 clean fill) -5.93 19.29SP20-CH-103-005 West (2003 clean fill) 13.1 25.7SP20-CH-103-010 West (2003 clean fill) -3.89 21.89SP20-CH-104-005 West (2003 clean fill) -3.31 20.3SP20-CH-104-010 West (2003 clean fill) -8.82 18.72SP20-CH-105-005 West (2003 clean fill) 11.43 19.88 7.48SP20-CH-105-010 West (2003 clean fill) 4.06 19.24SP20-CH-106-005 West (2003 clean fill) 6.28 19.47SP20-CH-106-010 West (2003 clean fill) 8.91 20.86SP20-CH-107-005D West (2003 clean fill) 3.27 24.01SP20-CH-108-005 North (undisturbed) 524.31 59.86 278.00 4.38SP20-CH-108-005D North (undisturbed) 197.68 40.49SP20-CH-108-010 North (undisturbed) 202.43 34.62SP20-CH-108-015 North (undisturbed) 673.27 66.19 1,160.00 2.99SP20-CH-108-015D North (undisturbed) 585.79 54.9SP20-CH-108-020 North (undisturbed) 168.93 38.37SP20-CH-109-005 North (undisturbed) 155.46 37.94SP20-CH-109-010 North (undisturbed) 271.41 50.15SP20-CH-109-015 North (undisturbed) 197.99 41.37SP20-CH-109-015D North (undisturbed) 250.48 44.21SP20-CH-109-020 North (undisturbed) 147.89 36.35SP20-CH-110-010 East (road & 2003 fill) 108.8 34.76SP20-CH-110-015 East (road & 2003 fill) 116.57 33.77SP20-CH-110-015D East (road & 2003 fill) 107.99 29.4SP20-CH-110-020 East (road & 2003 fill) 146.36 35.46SP20-CH-110-050 East (road & 2003 fill) 56.19 36.01SP20-CH-111-010 East (road & 2003 fill) 24.22 24.13SP20-CH-111-015 East (road & 2003 fill) -13.04 21.7SP20-CH-111-020 East (road & 2003 fill) 25.99 27.02SP20-CH-111-050 East (road & 2003 fill) 61.01 30.27SP20-CH-112-005 East (road & 2003 fill) 9.69 25.79SP20-CH-112-010 East (road & 2003 fill) 314.04 69.5SP20-CH-112-015 East (road & 2003 fill) 333.48 54.87 398.00SP20-CH-112-015D East (road & 2003 fill) 255.04 61.33SP20-CH-112-020 East (road & 2003 fill) 142.35 36.11SP20-CH-113-005 East (road & 2003 fill) 24.59 28.45SP20-CH-113-010 East (road & 2003 fill) 163.72 39.19SP20-CH-113-015 East (road & 2003 fill) 36.71 24.69

TCLP RESULTS

XRF Lead Measurement LAB ANALYTICAL

RESULTS SAMPLE IDMunicipal Garage Building Side (soil

condition)

TABLE 1RESULTS OF 2007 NOAA BUILDING PERIMETER INVESTIGATIN FOR LEAD IN SOIL

Municipal Garage Demolition St. Paul Island, AlaskaPage 2 of 2

Reading Error

mg/kg +/- mg/kg mg/kg mg/L

TCLP RESULTS

XRF Lead Measurement LAB ANALYTICAL

RESULTS SAMPLE IDMunicipal Garage Building Side (soil

condition)

SP20-CH-113-020 East (road & 2003 fill) -5.94 19.37SP20-CH-114-005 East (road & 2003 fill) 171.44 40.95 514.00SP20-CH-114-010 East (road & 2003 fill) 231.91 39.67SP20-CH-114-015 East (road & 2003 fill) 116.96 35.07SP20-CH-114-020 East (road & 2003 fill) 3.25 19.42SP20-CH-115-005 East (road & 2003 fill) 87.33 29.97SP20-CH-115-010 East (road & 2003 fill) 139.65 36.38SP20-CH-115-015 East (road & 2003 fill) 17.4 22.39SP20-CH-115-020 East (road & 2003 fill) -1.58 19.79


TABLE 2 SITE-SPECIFIC CLEANUP LEVELS FOR SOIL UNDER THE 10X RULE Municipal Garage

Demolition St. Paul Island, Alaska

Analysis Type Laboratory Method Cleanup Level, mg/kg Total Lead EPA 6020 1,000

GRO b AK-101 1,400 DRO b AK-102 2,500

Acenaphthenea EPA 8270C 210 Anthracenea EPA 8270C 4,300

Benzo(a)anthracenea EPA 8270C 6 Benzo(b)fluoranthenea EPA 8270C 11 Benzo(k)fluoranthenea EPA 8270C 110

Benzo(a)pyrenea EPA 8270C 1 Chrysenea EPA 8270C 620

Dibenzo(a,h)anthracenea EPA 8270C 1 Fluorenea EPA 8270C 270

Indeno(1,2,3-c,d)pyrenea EPA 8270C 11 Naphthalenea EPA 8270C 43

Pyrenea EPA 8270C 1,500 Benzeneb AK-101 0.5 Tolueneb AK-101 54

Ethylbenzeneb AK-101 55 Total Xylenesa AK-101 78

a These contaminants are still subject to the cleanup levels under Method Two, the chemical-specific cleanup levels for the PAHs indicated must be met unless ADEC determines that those cleanup levels need not be met to protect human health, safety, and welfare, and the environment (Note 15 to Method Two Tables B1 and B2). b ADEC has approved the use of the 10X rule for these contaminants. NOAA will elect to cleanup benzene in soils at 0.5 mg/kg in accordance with the TPA (see Section 1.0), and NOAA may elect to cleanup GRO, DRO, and other contaminants as appropriate under the Ten Times Rule (see Section 5.1.1 of NOAA’s Final CAP for this site (NOAA 2006b)).


TABLE 3 TCLP RESULTS FOR SIDING AND INTERIOR PLYWOOD TREATED WITH ECOBOND

Municipal Garage Demolition St. Paul Island, Alaska

Sample No./sampling location Parameter Results Units PQL Units

Analytical Method

Cleanup level Units

Exterior 001 TCLP Lead 0.749 mg/L 0.500 mg/LSW6010B

TCLP 5 mg/L


TCLP 5 mg/L

Exterior 003 TCLP Lead <0.500 mg/L 0.500 mg/LSW6010B

TCLP 5 mg/L


TCLP 5 mg/L


TCLP 5 mg/L


TCLP 5 mg/L


TCLP 5 mg/L

Interior 008 TCLP Lead <0.500 mg/L 0.500 mg/LSW6010B

TCLP 5 mg/L


TCLP 5 mg/L


TCLP 5 mg/L


TCLP 5 mg/L

< = Less than the value listed mg/L= Milligrams per Liter PQL = Practical Quantitation Limit

TABLE 4ANALYTICAL DATA SUMMARY -CONFIRMATION SAMPLE RESULTS


Sample No. Parameter Results PQLADEC

Cleanup level UnitsSP20-CS-100-020 Lead 23 0.238 1,000 mg/kgSP20-CS-001-020 Lead 18.7 0.215 1,000 mg/kgDuplicate of SP20-CS-001-020

SP20-CS-010-140 1-Methylnaphthalene 33.3 2.7 n/a mg/kg2-Methylnaphthalene 43.9 2.7 n/a mg/kgAcenaphthene 0.697 0.054 210 mg/kgAcenaphthylene 0 0.054 n/a mg/kgAnthracene 0.0356J 0.054 4,300 mg/kgBenzene 0 0.155 0.5 mg/kgBenzo(a)anthracene 0.082 0.054 6 mg/kgBenzo(a)pyrene 0.07 0.054 3 mg/kgBenzo(b)fluoranthene 0.0516J 0.054 20 mg/kgBenzo(g,h,i)perylene 0.0301J 0.054 n/a mg/kgBenzo(k)fluoranthene 0.0313J 0.054 200 mg/kgChrysene 0.0794 0.054 620 mg/kgDibenzo(a,h)anthracene 0 0.054 6 mg/kgDiesel Range Organics 10,900 1080 2,500 mg/kgEthylbenzene 8.87 0.297 5.5 mg/kgFluoranthene 0.143 0.054 2,100 mg/kgFluorene 0.882 0.054 270 mg/kgGasoline Range Organics 1,300 59.4 1,400 mg/kgIndeno(1,2,3-cd)pyrene 0.0262J 0.054 54 mg/kgNaphthalene 24.6 2.7 43 mg/kgo-Xylene 9.77 0.297 n/a mg/kgPhenanthrene 0.492 0.054 n/a mg/kgPyrene 0.255 0.054 1,500 mg/kgResidual Range Organics 217 21.6 10,000 mg/kgToluene 0.363J 0.594 54 mg/kgTotal Xylene 42.87 0.891 78 mg/kgXylene, Isomers m & p 33.1 0.594 n/a mg/kg

SP20-CS-011-060 Benzene 0 0.0141 0.5 mg/kgDiesel Range Organics 3.58J 21.9 2,500 mg/kgEthylbenzene 0.0349 0.0271 5.5 mg/kgGasoline Range Organics 2.95 2.71 1,400 mg/kgo-Xylene 0.122 0.0271 n/a mg/kgResidual Range Organics 9.31J 21.9 10,000 mg/kgToluene 0.0414J 0.0541 54 mg/kgTotal Xylene 0.34 0.0812 78 mg/kgXylene, Isomers m & p 0.218 0.0541 n/a mg/kg

4/8/2008Page 1 of 9




Cleanup level UnitsSP20-CS-023-130 Benzene 0 0.147 0.5 mg/kg

Diesel Range Organics 9,160 436 2,500 mg/kgEthylbenzene 5.26 0.283 5.5 mg/kgGasoline Range Organics 654 28.3 1,400 mg/kgo-Xylene 1.25 0.283 n/a mg/kgResidual Range Organics 1,180 218 10,000 mg/kgToluene 0.441J 0.566 54 mg/kgTotal Xylene 23.25 0.849 78 mg/kgXylene, Isomers m & p 22 0.566 n/a mg/kg

SP20-CS-024-130 Benzene 0 0.0124 0.5 mg/kgDiesel Range Organics 2,000 87.4 2,500 mg/kgEthylbenzene 1.98 0.0239 5.5 mg/kgGasoline Range Organics 206 11.9 1,400 mg/kgo-Xylene 2.32 0.239 n/a mg/kgResidual Range Organics 71.6J 87.4 10,000 mg/kgToluene 0.299 0.0477 54 mg/kgTotal Xylene 13.02 0.716 78 mg/kgXylene, Isomers m & p 10.7 0.477 n/a mg/kg

SP20-CS-025-130 Benzene 0.0867J 0.105 0.5 mg/kgDiesel Range Organics 2,710 117 2,500 mg/kgEthylbenzene 13.2 0.202 5.5 mg/kgGasoline Range Organics 487 20.2 1,400 mg/kgo-Xylene 21.1 2.02 n/a mg/kgResidual Range Organics 287 23.4 10,000 mg/kgToluene 13.3 0.403 54 mg/kgTotal Xylene 79.4 6.05 78 mg/kgXylene, Isomers m & p 58.3 4.03 n/a mg/kg

SP20-CS-027-130 Benzene 0 12.3 0.5 mg/kgDiesel Range Organics 10,200 445 2,500 mg/kgEthylbenzene 86.1 23.6 5.5 mg/kgGasoline Range Organics 3,160 236 1,400 mg/kgo-Xylene 134 23.6 n/a mg/kgResidual Range Organics 288 88.9 10,000 mg/kgToluene 35.4J 47.2 54 mg/kgTotal Xylene 552 70.8 78 mg/kgXylene, Isomers m & p 418 47.2 n/a mg/kg

SP20-CS-028-130 Benzene 0 0.0732 0.5 mg/kgGPS Point labeled as SP20-CH-028-130 Diesel Range Organics 8,690 434 2,500 mg/kg

Ethylbenzene 17.8 1.41 5.5 mg/kgGasoline Range Organics 529 14.1 1,400 mg/kgo-Xylene 19.1 1.41 n/a mg/kgResidual Range Organics 209 86.8 10,000 mg/kgToluene 3.52 0.281 54 mg/kgTotal Xylene 97.9 4.22 78 mg/kgXylene, Isomers m & p 78.8 2.81 n/a mg/kg

4/8/2008Page 2 of 9




Cleanup level UnitsSP20-CS-029-130 1,1,1-Trichloroethane 0 2.43 1.0 mg/kg

1,1,2,2-Tetrachloroethane 0 4.85 0.017 mg/kg1,1-Dichloroethane 0 2.43 12 mg/kg1,1-Dichloroethene 0 2.43 12 mg/kg1,2-Dichlorobenzene 0 2.43 7.0 mg/kg1,2-Dichloroethane 0 2.43 0.015 mg/kg1,2-Dichloropropane 0 2.43 0.017 mg/kg1,3-Dichlorobenzene 0 2.43 0.02 mg/kg1,4-Dichlorobenzene 0 2.43 0.8 mg/kg1-Methylnaphthalene 18 5.37 n/a mg/kg2-Methylnaphthalene 34 5.37 n/a mg/kgAcenaphthene 0.162 0.0537 210 mg/kgAcenaphthylene 0 0.0537 n/a mg/kgAnthracene 0.0286J 0.0537 4,300 mg/kgBenzene 0 1.26 0.5 mg/kgBenzo(a)anthracene 0.0261J 0.0537 6 mg/kgBenzo(a)pyrene 0 0.0537 3 mg/kgBenzo(b)fluoranthene 0 0.0537 20 mg/kgBenzo(g,h,i)perylene 0 0.0537 n/a mg/kgBenzo(k)fluoranthene 0.0274J 0.0537 200 mg/kgBromodichloromethane 0 2.43 0.35 mg/kgBromoform 0 2.43 0.38 mg/kgCarbon tetrachloride 0 2.43 0.03 mg/kgChlorobenzene 0 2.43 0.6 mg/kgChloroform 0 2.43 0.34 mg/kgChrysene 0.0279J 0.0537 620 mg/kgcis-1,2-Dichloroethene 0 2.43 0.2 mg/kgDibenzo(a,h)anthracene 0 0.0537 6 mg/kgDibromochloromethane 0 2.43 n/a mg/kgDiesel Range Organics 3,060 215 2,500 mg/kgEthylbenzene 86.1 2.43 5.5 mg/kgFluoranthene 0.0486J 0.0537 2,100 mg/kgFluorene 0.19 0.0537 270 mg/kgGasoline Range Organics 3,290 243 1,400 mg/kgIndeno(1,2,3-cd)pyrene 0 0.0537 54 mg/kgMethylene chloride 0 9.7 0.015 mg/kgNaphthalene 33.1 5.37 43 mg/kgo-Xylene 160 2.43 n/a mg/kgPhenanthrene 0.253 0.0537 n/a mg/kgPyrene 0.0941 0.0537 1,500 mg/kgResidual Range Organics 3,220 215 10,000 mg/kgTetrachloroethene 0 2.43 0.03 mg/kgToluene 53.7 4.85 54 mg/kgTotal Xylene 645 7.28 78 mg/kgtrans-1,2-Dichloroethene 0 2.43 0.4 mg/kgTrichloroethene 0 2.43 0.027 mg/kgXylene, Isomers m & p 485 4.85 n/a mg/kg

4/8/2008Page 3 of 9



SP20-CS-030-140

Xylene, Isomers m & p 0.0726 0.0487 n/a mg/kg


Cleanup level UnitsSP20-CS-110-130Duplicate of SP20-CS-029-130

1-Methylnaphthalene 20.5 5.38 n/a mg/kg

2-Methylnaphthalene 38 5.38 n/a mg/kgAcenaphthene 0.172 0.0538 210 mg/kgAcenaphthylene 0 0.0538 n/a mg/kgAnthracene 0.0298J 0.0538 4,300 mg/kgBenzene 0 11.1 0.5 mg/kgBenzo(a)anthracene 0.023J 0.0538 6 mg/kgBenzo(a)pyrene 0 0.0538 3 mg/kgBenzo(b)fluoranthene 0 0.0538 20 mg/kgBenzo(g,h,i)perylene 0 0.0538 n/a mg/kgBenzo(k)fluoranthene 0.0305J 0.0538 200 mg/kgChrysene 0.0258J 0.0538 620 mg/kgDibenzo(a,h)anthracene 0 0.0538 6 mg/kgDiesel Range Organics 3,770 214 2,500 mg/kgEthylbenzene 97.5 21.3 5.5 mg/kgFluoranthene 0.0498J 0.0538 2,100 mg/kgFluorene 0.204 0.0538 270 mg/kgGasoline Range Organics 3,430 213 1,400 mg/kgIndeno(1,2,3-cd)pyrene 0 0.0538 54 mg/kgNaphthalene 37.1 5.38 43 mg/kgo-Xylene 167 21.3 n/a mg/kgPhenanthrene 0.269 0.0538 n/a mg/kgPyrene 0 0.0538 1,500 mg/kgResidual Range Organics 4,000 214 10,000 mg/kgToluene 70.9 42.6 54 mg/kgTotal XyleneXylene, Isomers m & p

735568

63.942.6

78n/a

mg/kgmg/kg

1-Methylnaphthalene 0.0152 0.0066 n/a mg/kg2-Methylnaphthalene 0.009 0.0066 n/a mg/kgAcenaphthene 0.0032J 0.0066 210 mg/kgAcenaphthylene 0 0.0066 n/a mg/kgAnthracene 0 0.0066 4,300 mg/kgBenzene 0 0.0127 0.5 mg/kgBenzo(a)anthracene 0 0.0066 6 mg/kgBenzo(a)pyrene 0 0.0066 3 mg/kgBenzo(b)fluoranthene 0 0.0066 20 mg/kgBenzo(g,h,i)perylene 0.0021J 0.0066 n/a mg/kgBenzo(k)fluoranthene 0 0.0066 200 mg/kgChrysene 0 0.0066 620 mg/kgDibenzo(a,h)anthracene 0 0.0066 6 mg/kgDiesel Range Organics 62.3 26 2,500 mg/kgEthylbenzene 0.0102J 0.0244 5.5 mg/kgFluoranthene 0.0023J 0.0066 2,100 mg/kgFluorene 0.0041J 0.0066 270 mg/kgGasoline Range Organics 2.01J 2.44 1,400 mg/kgIndeno(1,2,3-cd)pyrene 0 0.0066 54 mg/kgNaphthalene 0.0132 0.0066 43 mg/kgo-Xylene 0.0202J 0.0244 n/a mg/kgPhenanthrene 0.0028J 0.0066 n/a mg/kgPyrene 0.0049J 0.0066 1,500 mg/kgResidual Range Organics 38.4 26 10,000 mg/kgToluene 0 0.0487 54 mg/kgTotal Xylene 0.0928J 0.0731 78 mg/kg

4/8/2008Page 4 of 9



SP20-CS-031-140

SP20-CS-032-140

SP20-CS-033-140

SP20-CS-034-140

SP20-CS-035-140

140



Cleanup level UnitsBenzene 0 0.0132 0.5 mg/kgDiesel Range Organics 3,280 220 2,500 mg/kgEthylbenzene 0.0132J 0.0254 5.5 mg/kgGasoline Range Organics 31 2.54 1,400 mg/kgo-Xylene 0 0.0254 n/a mg/kgResidual Range Organics 710 88.2 10,000 mg/kgToluene 0 0.0508 54 mg/kgTotal Xylene 0.0432J 0.0762 78 mg/kgXylene, Isomers m & p 0.0432J 0.0508 n/a mg/kgBenzene 0.0273 0.0165 0.5 mg/kgDiesel Range Organics 310 22.6 2,500 mg/kgEthylbenzene 0.0876 0.0317 5.5 mg/kgGasoline Range Organics 14.7 3.17 1,400 mg/kgo-Xylene 0.41 0.0317 n/a mg/kgResidual Range Organics 1,570 90.4 10,000 mg/kgToluene 0.145 0.0635 54 mg/kgTotal Xylene 1.45 0.0952 78 mg/kgXylene, Isomers m & p 1.04 0.0635 n/a mg/kgBenzene 0 0.0131 0.5 mg/kgDiesel Range Organics 3,310 217 2,500 mg/kgEthylbenzene 0 0.0251 5.5 mg/kgGasoline Range Organics 58.5 2.51 1,400 mg/kgo-Xylene 0 0.0251 n/a mg/kgResidual Range Organics 74.3J 86.7 10,000 mg/kgToluene 0 0.0503 54 mg/kgTotal Xylene 0 0.0754 78 mg/kgXylene, Isomers m & p 0 0.0503 n/a mg/kgBenzene 0 0.0106 0.5 mg/kgDiesel Range Organics 22.3 21.7 2,500 mg/kgEthylbenzene 0 0.0204 5.5 mg/kgGasoline Range Organics 1.84J 2.04 1,400 mg/kgo-Xylene 0.0072J 0.0204 n/a mg/kgResidual Range Organics 50.4 21.7 10,000 mg/kgToluene 0.0127J 0.0409 54 mg/kgTotal Xylene 0.0276J 0.0613 78 mg/kgXylene, Isomers m & p 0.0204J 0.0409 n/a mg/kgBenzene 0 0.0111 0.5 mg/kgDiesel Range Organics 21.1J 21.2 2,500 mg/kgEthylbenzene 0.0486 0.0213 5.5 mg/kgGasoline Range Organics 9.06 2.13 1,400 mg/kgo-Xylene 0.27 0.0213 n/a mg/kgResidual Range Organics 34.8 21.2 10,000 mg/kgToluene 0.0203J 0.0427 54 mg/kgTotal Xylene 0.914 0.064 78 mg/kgXylene, Isomers m & p 0.644 0.0427 n/a mg/kg

SP20-CS-115-140Duplicate of SP20-CS-035-

Benzene 0 0.0119 0.5 mg/kg

Diesel Range Organics 54J 85.2 2,500 mg/kgEthylbenzene 0.187 0.0228 5.5 mg/kgGasoline Range Organics 37.9 4.56 1,400 mg/kgo-Xylene 1.07 0.0228 n/a mg/kgResidual Range Organics 85.6 85.2 10,000 mg/kgToluene 0.0285J 0.0456 54 mg/kgTotal Xylene 3.63 0.0684 78 mg/kg

4/8/2008Page 5 of 9



SP20-CS-303-140

SP20-CS-304-120

SP20-CS-305-100

SP20-CS-306-140

Xylene, Isomers m & p 56 4.78 n/a mg/kg

4/8/2008Page 6 of 9

ADEC Sample No. Parameter Results PQL Cleanup level Units

1-Methylnaphthalene 16.2 2.87 n/a mg/kg2-Methylnaphthalene 21.3 2.87 n/a mg/kgAcenaphthene 0.0276J 0.0575 210 mg/kgAcenaphthylene 0 0.0575 n/a mg/kgAnthracene 0 0.0575 4,300 mg/kgBenzene 0 0.142 0.5 mg/kgBenzo(a)anthracene 0 0.0575 6 mg/kgBenzo(a)pyrene 0 0.0575 3 mg/kgBenzo(b)fluoranthene 0 0.0575 20 mg/kgBenzo(g,h,i)perylene 0 0.0575 n/a mg/kgBenzo(k)fluoranthene 0 0.0575 200 mg/kgChrysene 0 0.0575 620 mg/kgDibenzo(a,h)anthracene 0 0.0575 6 mg/kgDiesel Range Organics 309 23.1 2,500 mg/kgEthylbenzene 2.46 0.273 5.5 mg/kgFluoranthene 0 0.0575 2,100 mg/kgFluorene 0.0375J 0.0575 270 mg/kgGasoline Range Organics 330 136 1,400 mg/kgIndeno(1,2,3-cd)pyrene 0 0.0575 54 mg/kgNaphthalene 10.7 2.87 43 mg/kgo-Xylene 6.09 0.273 n/a mg/kgPhenanthrene 0.0568J 0.0575 n/a mg/kgPyrene 0.0218J 0.0575 1,500 mg/kgResidual Range Organics 436 23.1 10,000 mg/kgToluene 2.29 0.546 54 mg/kgTotal Xylenes 23.6 0.819 78 mg/kgXylene, Isomers m & p 17.5 0.546 n/a mg/kgBenzene 0 0.015 0.5 mg/kgDiesel Range Organics 569 23 2,500 mg/kgEthylbenzene 0.0793 0.0289 5.5 mg/kgGasoline Range Organics 38.1 2.89 1,400 mg/kgo-Xylene 0.245 0.0289 n/a mg/kgResidual Range Organics 580 23 10,000 mg/kgToluene 0.0915 0.0579 54 mg/kgTotal Xylenes 0.727 0.0868 78 mg/kgXylene, Isomers m & p 0.482 0.0579 n/a mg/kgBenzene 0 0.0112 0.5 mg/kgDiesel Range Organics 2.75J 21.8 2,500 mg/kgEthylbenzene 0 0.0215 5.5 mg/kgGasoline Range Organics 0.854J 2.15 1,400 mg/kgo-Xylene 0.0071J 0.0215 n/a mg/kgResidual Range Organics 13.4J 21.8 10,000 mg/kgToluene 0 0.043 54 mg/kgTotal Xylenes 0.0254J 0.0645 78 mg/kgXylene, Isomers m & p 0.0183J 0.043 n/a mg/kgBenzene 0 1.24 0.5 mg/kgDiesel Range Organics 565 24.1 2,500 mg/kgEthylbenzene 9.92 2.39 5.5 mg/kgGasoline Range Organics 739 239 1,400 mg/kgo-Xylene 18.6 2.39 n/a mg/kgResidual Range Organics 130 24.1 10,000 mg/kgToluene 11.1 4.78 54 mg/kgTotal Xylenes 74.6 7.17 78 mg/kg



SP20-CS-308-130

Duplicate of CS-308-130

SP20-CS-309-140

SP20-CS-311-100

SP20-CS-312-100

Xylene, Isomers m & p 0.0301J 0.0627 n/a mg/kg

4/8/2008Page 7 of 9


Benzene 0 1.04 0.5 mg/kgDiesel Range Organics 30.9 23.2 2,500 mg/kgEthylbenzene 12.7 1.99 5.5 mg/kgGasoline Range Organics 686 99.7 1,400 mg/kgo-Xylene 19.3 1.99 n/a mg/kgResidual Range Organics 28.2B 23.2 10,000 mg/kgToluene 40.4 3.99 54 mg/kgTotal Xylenes 76.3 5.98 78 mg/kgXylene, Isomers m & p 57 3.99 n/a mg/kg

SP20-CS-401-130 Benzene 0.639J 1.38 0.5 mg/kgDiesel Range Organics 55.6 23.5 2,500 mg/kgEthylbenzene 41.5 2.66 5.5 mg/kgGasoline Range Organics 2,040 133 1,400 mg/kgo-Xylene 57 2.66 n/a mg/kgResidual Range Organics 36.7B 23.5 10,000 mg/kgToluene 123 5.32 54 mg/kgTotal Xylenes 237 7.98 78 mg/kgXylene, Isomers m & p 180 5.32 n/a mg/kgBenzene 0 0.153 0.5 mg/kgDiesel Range Organics 4.81J 25.9 2,500 mg/kgEthylbenzene 2.78 0.294 5.5 mg/kgGasoline Range Organics 96.3 14.7 1,400 mg/kgo-Xylene 3.7 0.294 n/a mg/kgResidual Range Organics 18.9J 25.9 10,000 mg/kgToluene 3.63 0.588 54 mg/kgTotal Xylenes 16 0.882 78 mg/kgXylene, Isomers m & p 12.3 0.588 n/a mg/kgBenzene 0 0.0193 0.5 mg/kgDiesel Range Organics 4.3J 22.5 2,500 mg/kgEthylbenzene 0.0887 0.0371 5.5 mg/kgGasoline Range Organics 0 3.71 1,400 mg/kgo-Xylene 0.13 0.0371 n/a mg/kgResidual Range Organics 28.6B 22.5 10,000 mg/kgToluene 0.135 0.0742 54 mg/kgTotal Xylenes 0.567 0.1113 78 mg/kgXylene, Isomers m & p 0.437 0.0742 n/a mg/kgBenzene 0 0.0163 0.5 mg/kgDiesel Range Organics 3.53J 21.8 2,500 mg/kgEthylbenzene 0 0.0314 5.5 mg/kgGasoline Range Organics 0 3.14 1,400 mg/kgo-Xylene 0 0.0314 n/a mg/kgResidual Range Organics 15.9J 21.8 10,000 mg/kgToluene 0 0.0627 54 mg/kgTotal Xylenes 0.0301J 0.0941 78 mg/kg



SP20-CS-303-140

SP20-CS-304-120

SP20-CS-305-100

SP20-CS-306-140

Xylene, Isomers m & p 56 4.78 n/a mg/kg

4/8/2008Page 8 of 9


1-Methylnaphthalene 16.2 2.87 n/a mg/kg2-Methylnaphthalene 21.3 2.87 n/a mg/kgAcenaphthene 0.0276J 0.0575 210 mg/kgAcenaphthylene 0 0.0575 n/a mg/kgAnthracene 0 0.0575 4,300 mg/kgBenzene 0 0.142 0.5 mg/kgBenzo(a)anthracene 0 0.0575 6 mg/kgBenzo(a)pyrene 0 0.0575 3 mg/kgBenzo(b)fluoranthene 0 0.0575 20 mg/kgBenzo(g,h,i)perylene 0 0.0575 n/a mg/kgBenzo(k)fluoranthene 0 0.0575 200 mg/kgChrysene 0 0.0575 620 mg/kgDibenzo(a,h)anthracene 0 0.0575 6 mg/kgDiesel Range Organics 309 23.1 2,500 mg/kgEthylbenzene 2.46 0.273 5.5 mg/kgFluoranthene 0 0.0575 2,100 mg/kgFluorene 0.0375J 0.0575 270 mg/kgGasoline Range Organics 330 136 1,400 mg/kgIndeno(1,2,3-cd)pyrene 0 0.0575 54 mg/kgNaphthalene 10.7 2.87 43 mg/kgo-Xylene 6.09 0.273 n/a mg/kgPhenanthrene 0.0568J 0.0575 n/a mg/kgPyrene 0.0218J 0.0575 1,500 mg/kgResidual Range Organics 436 23.1 10,000 mg/kgToluene 2.29 0.546 54 mg/kgTotal Xylenes 23.6 0.819 78 mg/kgXylene, Isomers m & p 17.5 0.546 n/a mg/kgBenzene 0 0.015 0.5 mg/kgDiesel Range Organics 569 23 2,500 mg/kgEthylbenzene 0.0793 0.0289 5.5 mg/kgGasoline Range Organics 38.1 2.89 1,400 mg/kgo-Xylene 0.245 0.0289 n/a mg/kgResidual Range Organics 580 23 10,000 mg/kgToluene 0.0915 0.0579 54 mg/kgTotal Xylenes 0.727 0.0868 78 mg/kgXylene, Isomers m & p 0.482 0.0579 n/a mg/kgBenzene 0 0.0112 0.5 mg/kgDiesel Range Organics 2.75J 21.8 2,500 mg/kgEthylbenzene 0 0.0215 5.5 mg/kgGasoline Range Organics 0.854J 2.15 1,400 mg/kgo-Xylene 0.0071J 0.0215 n/a mg/kgResidual Range Organics 13.4J 21.8 10,000 mg/kgToluene 0 0.043 54 mg/kgTotal Xylenes 0.0254J 0.0645 78 mg/kgXylene, Isomers m & p 0.0183J 0.043 n/a mg/kgBenzene 0 1.24 0.5 mg/kgDiesel Range Organics 565 24.1 2,500 mg/kgEthylbenzene 9.92 2.39 5.5 mg/kgGasoline Range Organics 739 239 1,400 mg/kgo-Xylene 18.6 2.39 n/a mg/kgResidual Range Organics 130 24.1 10,000 mg/kgToluene 11.1 4.78 54 mg/kgTotal Xylenes 74.6 7.17 78 mg/kg



SP20-CS-308-130

SP20-CS-309-140

SP20-CS-311-100

SP20-CS-312-100

SP20-CS-401-130

PQL = Practical Quantitation Limit

4/8/2008Page 9 of 9


Benzene 0 1.04 0.5 mg/kgDiesel Range Organics 30.9 23.2 2,500 mg/kgEthylbenzene 12.7 1.99 5.5 mg/kgGasoline Range Organics 686 99.7 1,400 mg/kgo-Xylene 19.3 1.99 n/a mg/kgResidual Range Organics 28.2B 23.2 10,000 mg/kgToluene 40.4 3.99 54 mg/kgTotal Xylenes 76.3 5.98 78 mg/kgXylene, Isomers m & p 57 3.99 n/a mg/kgBenzene 0 0.153 0.5 mg/kgDiesel Range Organics 4.81J 25.9 2,500 mg/kgEthylbenzene 2.78 0.294 5.5 mg/kgGasoline Range Organics 96.3 14.7 1,400 mg/kgo-Xylene 3.7 0.294 n/a mg/kgResidual Range Organics 18.9J 25.9 10,000 mg/kgToluene 3.63 0.588 54 mg/kgTotal Xylenes 16 0.882 78 mg/kgXylene, Isomers m & p 12.3 0.588 n/a mg/kgBenzene 0 0.0193 0.5 mg/kgDiesel Range Organics 4.3J 22.5 2,500 mg/kgEthylbenzene 0.0887 0.0371 5.5 mg/kgGasoline Range Organics 0 3.71 1,400 mg/kgo-Xylene 0.13 0.0371 n/a mg/kgResidual Range Organics 28.6B 22.5 10,000 mg/kgToluene 0.135 0.0742 54 mg/kgTotal Xylenes 0.567 0.1113 78 mg/kgXylene, Isomers m & p 0.437 0.0742 n/a mg/kgBenzene 0 0.0163 0.5 mg/kgDiesel Range Organics 3.53J 21.8 2,500 mg/kgEthylbenzene 0 0.0314 5.5 mg/kgGasoline Range Organics 0 3.14 1,400 mg/kgo-Xylene 0 0.0314 n/a mg/kgResidual Range Organics 15.9J 21.8 10,000 mg/kgToluene 0 0.0627 54 mg/kgTotal Xylenes 0.0301J 0.0941 78 mg/kgXylene, Isomers m & p 0.0301J 0.0627 n/a mg/kgBenzene 0.639J 1.38 0.5 mg/kgDiesel Range Organics 55.6 23.5 2,500 mg/kgEthylbenzene 41.5 2.66 5.5 mg/kgGasoline Range Organics 2040 133 1,400 mg/kgo-Xylene 57 2.66 n/a mg/kgResidual Range Organics 36.7B 23.5 10,000 mg/kgToluene 123 5.32 54 mg/kgTotal Xylenes 237 7.98 78 mg/kgXylene, Isomers m & p 180 5.32 n/a mg/kg

Bold numbers indicate greater than ADEC cleanup levels.J = Estimated value due to value less than PQLB = EPA Flag - Analyte present in the blank and the sampleCL = Initial analysis within holding time but required dilutionGRO = Gasoline Range OrganicsDRO = Diesel Range OrganicsRRO = Residual Range Organicsmg/Kg = Milligrams per Kilogram

TABLE 5ANALYTICAL DATA SUMMARY -CHARACTERIZATION SAMPLE RESULTS



Cleanup level UnitsSP20-CH-002 1-Methylnaphthalene 0.216 0.0591 n/a mg/kg

2-Methylnaphthalene 0.0791 0.0591 n/a mg/kgAcenaphthene 0 0.0591 210 mg/kgAcenaphthylene 0 0.0591 n/a mg/kgAnthracene 0 0.0591 4,300 mg/kgBenzene 0 0.0165 0.5 mg/kgBenzo(a)anthracene 0 0.0591 6 mg/kgBenzo(a)pyrene 0 0.0591 3 mg/kgBenzo(b)fluoranthene 0 0.0591 20 mg/kgBenzo(g,h,i)perylene 0 0.0591 n/a mg/kgBenzo(k)fluoranthene 0 0.0591 200 mg/kgChrysene 0 0.0591 620 mg/kgDibenzo(a,h)anthracene 0 0.0591 6 mg/kgDiesel Range Organics 265 23.9 2,500 mg/kgEthylbenzene 0.034 0.0318 5.5 mg/kgFluoranthene 0.0219J 0.0591 2,100 mg/kgFluorene 0.0251J 0.0591 270 mg/kgGasoline Range Organics 55.6 3.18 1,400 mg/kgIndeno(1,2,3-cd)pyrene 0 0.0591 54 mg/kgNaphthalene 0.023J 0.0591 43 mg/kgo-Xylene 0.027J 0.0318 n/a mg/kgPhenanthrene 0.0388J 0.0591 n/a mg/kgPyrene 0.046J 0.0591 1,500 mg/kgResidual Range Organics 52 23.9 10,000 mg/kgToluene 0.0216J 0.0635 54 mg/kgTotal Xylene 0.168J 0.0953 78 mg/kgXylene, Isomers m & p 0.141 0.0635 n/a mg/kg

SP20-CH-003 Benzene 0.0111J 0.0156 0.5 mg/kgDiesel Range Organics 261 21.6 2,500 mg/kgEthylbenzene 0 0.0301 5.5 mg/kgGasoline Range Organics 3.03 3.01 1,400 mg/kgo-Xylene 0.031 0.0301 n/a mg/kgResidual Range Organics 157 21.6 10,000 mg/kgToluene 0.0539J 0.0602 54 mg/kgTotal Xylene 0.0849J 0.0903 78 mg/kgXylene, Isomers m & p 0.0539J 0.0602 n/a mg/kg

4/8/2008Page 1 of 7




Cleanup level UnitsSP20-CH-004 1-Methylnaphthalene 0.0455J 0.0557 n/a mg/kg

2-Methylnaphthalene 0.0395J 0.0557 n/a mg/kgAcenaphthene 0 0.0557 210 mg/kgAcenaphthylene 0 0.0557 n/a mg/kgAnthracene 0 0.0557 4,300 mg/kgBenzene 0.0475 0.0133 0.5 mg/kgBenzo(a)anthracene 0.0462J 0.0557 6 mg/kgBenzo(a)pyrene 0.0592 0.0557 3 mg/kgBenzo(b)fluoranthene 0.0483J 0.0557 20 mg/kgBenzo(g,h,i)perylene 0.0748 0.0557 n/a mg/kgBenzo(k)fluoranthene 0.0265J 0.0557 200 mg/kgChrysene 0.0375J 0.0557 620 mg/kgDibenzo(a,h)anthracene 0 0.0557 6 mg/kgDiesel Range Organics 417 22.1 2,500 mg/kgEthylbenzene 0.0107J 0.0255 5.5 mg/kgFluoranthene 0.0435J 0.0557 2,100 mg/kgFluorene 0 0.0557 270 mg/kgGasoline Range Organics 4.51 2.55 1,400 mg/kgIndeno(1,2,3-cd)pyrene 0.0545J 0.0557 54 mg/kgNaphthalene 0.0345J 0.0557 43 mg/kgo-Xylene 0.0641 0.0255 n/a mg/kgPhenanthrene 0.0514J 0.0557 n/a mg/kgPyrene 0.0791 0.0557 1,500 mg/kgResidual Range Organics 284 22.1 10,000 mg/kgToluene 0.0996 0.0511 54 mg/kgTotal Xylene 0.1961 0.0766 78 mg/kgXylene, Isomers m & p 0.132 0.0511 n/a mg/kg

SP20-CH-008-140 Benzene 0 0.133 0.5 mg/kgConfirmation Sample mislabeled

Diesel Range Organics 5,960 245 2,500 mg/kgEthylbenzene 3.74 0.257 5.5 mg/kgGasoline Range Organics 205 12.8 1,400 mg/kgo-Xylene 6.22 0.257 n/a mg/kgResidual Range Organics 44.5 24.5 10,000 mg/kgToluene 0.19J 0.513 54 mg/kgTotal Xylene 22.42 0.77 78 mg/kgXylene, Isomers m & p 16.2 0.513 n/a mg/kg

4/8/2008Page 2 of 7




Cleanup level UnitsSP20-CH-009 1-Methylnaphthalene 2.38 0.273 n/a mg/kg

2-Methylnaphthalene 3.12 0.273 n/a mg/kgAcenaphthene 0.0625 0.0546 210 mg/kgAcenaphthylene 0 0.0546 n/a mg/kgAnthracene 0 0.0546 4,300 mg/kgBenzene 0 0.124 0.5 mg/kgBenzo(a)anthracene 0 0.0546 6 mg/kgBenzo(a)pyrene 0 0.0546 3 mg/kgBenzo(b)fluoranthene 0 0.0546 20 mg/kgBenzo(g,h,i)perylene 0 0.0546 n/a mg/kgBenzo(k)fluoranthene 0 0.0546 200 mg/kgChrysene 0 0.0546 620 mg/kgDibenzo(a,h)anthracene 0 0.0546 6 mg/kgDiesel Range Organics 1,950 86.9 2,500 mg/kgEthylbenzene 1.68 0.238 5.5 mg/kgFluoranthene 0.0197 0.0546 2,100 mg/kgFluorene 0.0825J 0.0546 270 mg/kgGasoline Range Organics 286 11.9 1,400 mg/kgIndeno(1,2,3-cd)pyrene 0 0.0546 54 mg/kgNaphthalene 1.43 0.273 43 mg/kgo-Xylene 0.845 0.238 n/a mg/kgPhenanthrene 0.057 0.0546 n/a mg/kgPyrene 0.0399J 0.0546 1,500 mg/kgResidual Range Organics 149 21.7 10,000 mg/kgToluene 0.466J 0.476 54 mg/kgTotal Xylene 7.045 0.714 78 mg/kgXylene, Isomers m & p 6.2 0.476 n/a mg/kg

SP20-CH-012 Benzene 0 1.47 0.5 mg/kgDiesel Range Organics 5,510 219 2,500 mg/kgEthylbenzene 20.6 2.83 5.5 mg/kgGasoline Range Organics 938 28.3 1,400 mg/kgo-Xylene 37.8 2.83 n/a mg/kgResidual Range Organics 523 21.9 10,000 mg/kgToluene 11.4 5.66 54 mg/kgTotal Xylene 141.8 8.49 78 mg/kgXylene, Isomers m & p 104 5.66 n/a mg/kg

4/8/2008Page 3 of 7



SP20-CH-013

Duplicate of SP20-CH-013



Cleanup level Units1-Methylnaphthalene 15.3 1.21 n/a mg/kg2-Methylnaphthalene 21.5 1.21 n/a mg/kgAcenaphthene 0.206 0.0605 210 mg/kgAcenaphthylene 0 0.0605 n/a mg/kgAnthracene 0 0.0605 4,300 mg/kgBenzene 0 0.139 0.5 mg/kgBenzo(a)anthracene 0.0208J 0.0605 6 mg/kgBenzo(a)pyrene 0 0.0605 3 mg/kgBenzo(b)fluoranthene 0 0.0605 20 mg/kgBenzo(g,h,i)perylene 0 0.0605 n/a mg/kgBenzo(k)fluoranthene 0 0.0605 200 mg/kgChrysene 0 0.0605 620 mg/kgDibenzo(a,h)anthracene 0 0.0605 6 mg/kgDiesel Range Organics 2,120 95.9 2,500 mg/kgEthylbenzene 4.55 0.268 5.5 mg/kgFluoranthene 0.0385J 0.0605 2,100 mg/kgFluorene 0.264 0.0605 270 mg/kgGasoline Range Organics 185 5.36 1,400 mg/kgIndeno(1,2,3-cd)pyrene 0 0.0605 54 mg/kgNaphthalene 12.7 1.21 43 mg/kgo-Xylene 2.49 0.268 n/a mg/kgPhenanthrene 0.161 0.0605 n/a mg/kgPyrene 0.0708 0.0605 1,500 mg/kgResidual Range Organics 45.7 24 10,000 mg/kgToluene 0.172J 0.536 54 mg/kgTotal XyleneXylene, Isomers m & p

21.3918.9

0.8040.536

78n/a

mg/kgmg/kg

SP20-CH-0991-Methylnaphthalene 7.42 0.605 n/a mg/kg2-Methylnaphthalene 10.4 0.605 n/a mg/kgAcenaphthene 0.214 0.0605 210 mg/kgAcenaphthylene 0 0.0605 n/a mg/kgAnthracene 0 0.0605 4,300 mg/kgBenzene 0 0.116 0.5 mg/kgBenzo(a)anthracene 0.0203J 0.0605 6 mg/kgBenzo(a)pyrene 0 0.0605 3 mg/kgBenzo(b)fluoranthene 0 0.0605 20 mg/kgBenzo(g,h,i)perylene 0 0.0605 n/a mg/kgBenzo(k)fluoranthene 0 0.0605 200 mg/kgChrysene 0.0183J 0.0605 620 mg/kgDibenzo(a,h)anthracene 0 0.0605 6 mg/kgDiesel Range Organics 1,310 96.6 2,500 mg/kgEthylbenzene 2.75 0.223 5.5 mg/kgFluoranthene 0.0422 0.0605 2,100 mg/kgFluorene 0.27J 0.0605 270 mg/kgGasoline Range Organics 118 4.45 1,400 mg/kgIndeno(1,2,3-cd)pyrene 0 0.0605 54 mg/kgNaphthalene 5.92 0.605 43 mg/kgo-Xylene 1.59 0.223 n/a mg/kgPhenanthrene 0.175 0.0605 n/a mg/kgPyrene 0.0753 0.0605 1,500 mg/kgResidual Range Organics 54.5 24.1 10,000 mg/kgToluene 0 0.445 54 mg/kgTotal Xylene 12.99 0.668 78 mg/kg

4/8/2008Page 4 of 7



SP20-CH-015

SP20-CH-016

SP20-CH-017

SP20-CH-018


mislabeled


SP20-CH-014-140Confirmation Sample

Benzene 0 0.123 0.5 mg/kgDiesel Range Organics 10,600 437 2,500 mg/kgEthylbenzene 17.9 2.36 5.5 mg/kgGasoline Range Organics 1,600 236 1,400 mg/kgo-Xylene 61.9 2.36 n/a mg/kgResidual Range Organics 2,410 437 10,000 mg/kgToluene 9.2 4.72 54 mg/kgTotal Xylene 231.9 7.08 78 mg/kgXylene, Isomers m & p 170 4.72 n/a mg/kgBenzene 0 0.0959 0.5 mg/kgDiesel Range Organics 6,050 232 2,500 mg/kgEthylbenzene 1.92 0.184 5.5 mg/kgGasoline Range Organics 139 18.4 1,400 mg/kgo-Xylene 1.58 0.184 n/a mg/kgResidual Range Organics 60.5 23.2 10,000 mg/kgToluene 0 0.369 54 mg/kgTotal Xylene 8.64 0.553 78 mg/kgXylene, Isomers m & p 7.06 0.369 n/a mg/kgBenzene 0 0.016 0.5 mg/kgDiesel Range Organics 3.04J 21.2 2,500 mg/kgEthylbenzene 0 0.0308 5.5 mg/kgGasoline Range Organics 2.01J 3.08 1,400 mg/kgo-Xylene 0 0.0308 n/a mg/kgResidual Range Organics 11J 21.2 10,000 mg/kgToluene 0 0.0616 54 mg/kgTotal Xylene 0 0.0924 78 mg/kgXylene, Isomers m & p 0 0.0616 n/a mg/kgBenzene 0 0.0181 0.5 mg/kgDiesel Range Organics 55.4 23.8 2,500 mg/kgEthylbenzene 0 0.0349 5.5 mg/kgGasoline Range Organics 1.51J 3.49 1,400 mg/kgo-Xylene 0 0.0349 n/a mg/kgResidual Range Organics 159 23.8 10,000 mg/kgToluene 0 0.0698 54 mg/kgTotal Xylene 0.000 0.1047 78 mg/kgXylene, Isomers m & p 0 0.0698 n/a mg/kgBenzene 0 0.0122 0.5 mg/kgDiesel Range Organics 6,860 214 2,500 mg/kgEthylbenzene 1.32 0.234 5.5 mg/kgGasoline Range Organics 0.831J 2.34 1,400 mg/kgo-Xylene 1.28 0.234 n/a mg/kgResidual Range Organics 4,580 214 10,000 mg/kgToluene 0 0.468 54 mg/kgTotal Xylene 7.99 0.702 78 mg/kg

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SP20-CH-019

SP20-CH-020

SP20-CH-022

Connector Pad

Xylene, Isomers m & p 0.0207J 0.0657 n/a mg/kg

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Benzene 0 0.0139 0.5 mg/kgDiesel Range Organics 4,290 214 2,500 mg/kgEthylbenzene 0 0.0266 5.5 mg/kgGasoline Range Organics 159 13.3 1,400 mg/kgo-Xylene 0 0.0266 n/a mg/kgResidual Range Organics 668 21.4 10,000 mg/kgToluene 0 0.0533 54 mg/kgTotal Xylene 0 0.0799 78 mg/kgXylene, Isomers m & p 0 0.0533 n/a mg/kgBenzene 0 0.0153 0.5 mg/kgDiesel Range Organics 3.01J 21.6 2,500 mg/kgEthylbenzene 0 0.0295 5.5 mg/kgGasoline Range Organics 1.83J 2.95 1,400 mg/kgo-Xylene 0 0.0295 n/a mg/kgResidual Range Organics 13.4J 21.6 10,000 mg/kgToluene 0 0.0589 54 mg/kgTotal Xylene 0 0.0884 78 mg/kgXylene, Isomers m & p 0 0.0589 n/a mg/kgBenzene 0 0.0106 0.5 mg/kgDiesel Range Organics 23.4 21.6 2,500 mg/kgEthylbenzene 0 0.0205 5.5 mg/kgGasoline Range Organics 0.697J 2.05 1,400 mg/kgo-Xylene 0.0076J 0.0205 n/a mg/kgResidual Range Organics 24.2 21.6 10,000 mg/kgToluene 0 0.041 54 mg/kgTotal Xylene 0.0076J 0.0615 78 mg/kgXylene, Isomers m & p 0 0.041 n/a mg/kg

SP20-CH-301 1-Methylnaphthalene 0.15 0.0568 n/a mg/kg2-Methylnaphthalene 0.172 0.0568 n/a mg/kgAcenaphthene 0 0.0568 210 mg/kgAcenaphthylene 0 0.0568 n/a mg/kgAnthracene 0 0.0568 4,300 mg/kgBenzene 0 0.0171 0.5 mg/kgBenzo(a)anthracene 0 0.0568 6 mg/kgBenzo(a)pyrene 0 0.0568 3 mg/kgBenzo(b)fluoranthene 0 0.0568 20 mg/kgBenzo(g,h,i)perylene 0 0.0568 n/a mg/kgBenzo(k)fluoranthene 0 0.0568 200 mg/kgChrysene 0 0.0568 620 mg/kgDibenzo(a,h)anthracene 0 0.0568 6 mg/kgDiesel Range Organics 110 22.6 2,500 mg/kgEthylbenzene 0 0.0329 5.5 mg/kgFluoranthene 0 0.0568 2,100 mg/kgFluorene 0 0.0568 270 mg/kgGasoline Range Organics 0.76J 3.29 1,400 mg/kgIndeno(1,2,3-cd)pyrene 0 0.0568 54 mg/kgNaphthalene 0.0865 0.0568 43 mg/kgo-Xylene 0 0.0329 n/a mg/kgPhenanthrene 0 0.0568 n/a mg/kgPyrene 0 0.0568 1,500 mg/kgResidual Range Organics 706 22.6 10,000 mg/kgToluene 0.024J 0.0657 54 mg/kgTotal Xylene 0.0207J 0.0986 78 mg/kg



Connector Pad

Connector Pad

Connector Pad

Connector Pad


PQL = Practical Quantitation Limit

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SP20-CH-302 Benzene 0.0338 0.0148 0.5 mg/kgDiesel Range Organics 438 22.9 2,500 mg/kgEthylbenzene 0.525 0.0284 5.5 mg/kgGasoline Range Organics 97.3 2.84 1,400 mg/kgo-Xylene 2.96 0.284 n/a mg/kgResidual Range Organics 1,190 91.4 10,000 mg/kgToluene 0.572 0.0568 54 mg/kgTotal Xylene 11.68 0.852 78 mg/kgXylene, Isomers m & p 8.72 0.568 n/a mg/kg

SP20-CH-307 Benzene 0 0.0121 0.5 mg/kgDiesel Range Organics 65.6 21.6 2,500 mg/kgEthylbenzene 0 0.0233 5.5 mg/kgGasoline Range Organics 9.36 2.33 1,400 mg/kgo-Xylene 0.275 0.0233 n/a mg/kgResidual Range Organics 103B 21.6 10,000 mg/kgToluene 0 0.0465 54 mg/kgTotal Xylene 0.375 0.0698 78 mg/kgXylene, Isomers m & p 0.0996 0.0465 n/a mg/kg

SP20-CH-310 Benzene 0 0.0132 0.5 mg/kgDiesel Range Organics 4.77J 21.4 2,500 mg/kgEthylbenzene 0 0.0253 5.5 mg/kgGasoline Range Organics 1.08J 2.53 1,400 mg/kgo-Xylene 0.0403 0.0253 n/a mg/kgResidual Range Organics 12.4J 21.4 10,000 mg/kgToluene 0 0.0507 54 mg/kgTotal Xylene 0.1011 0.076 78 mg/kgXylene, Isomers m & p 0.0608 0.0507 n/a mg/kg

SP20-CH-400 Benzene 0 0.0154 0.5 mg/kgDiesel Range Organics 85.7 21.9 2,500 mg/kgEthylbenzene 0.011J 0.0296 5.5 mg/kgGasoline Range Organics 2.6 2.01 1,400 mg/kgo-Xylene 0.111 0.0296 n/a mg/kgResidual Range Organics 113 21.9 10,000 mg/kgToluene 0.059J 0.0593 54 mg/kgTotal Xylene 0.182 0.0889 78 mg/kg

Bold numbers indicate greater than ADEC cleanup levels.J = Estimated value due to value less than PQLB = EPA Flag - Analyte present in the blank and the sampleCL = Initial analysis within holding time but required dilutionGRO = Gasoline Range OrganicsDRO = Diesel Range OrganicsRRO = Residual Range Organicsmg/Kg = Milligrams per Kilogram

TABLE 6BACKFILL CHARACTERIZATION SAMPLE RESULTS



Cleanup level UnitsSP20-CB-005 1-Methylnaphthalene 0 0.0056 n/a mg/kg

2-Methylnaphthalene 0 0.0056 n/a mg/kgAcenaphthene 0 0.0056 210 mg/kgAcenaphthylene 0 0.0056 n/a mg/kgAnthracene 0 0.0056 4,300 mg/kgBenzene 0 0.017 0.5 mg/kgBenzo(a)anthracene 0 0.0056 6 mg/kgBenzo(a)pyrene 0 0.0056 3 mg/kgBenzo(b)fluoranthene 0 0.0056 20 mg/kgBenzo(g,h,i)perylene 0 0.0056 n/a mg/kgBenzo(k)fluoranthene 0 0.0056 200 mg/kgChrysene 0 0.0056 620 mg/kgDibenzo(a,h)anthracene 0 0.0056 6 mg/kgDiesel Range Organics 2.64J 22.2 2,500 mg/kgEthylbenzene 0 0.0326 5.5 mg/kgFluoranthene 0 0.0056 2,100 mg/kgFluorene 0 0.0056 270 mg/kgGasoline Range Organics 0.743J 3.26 1,400 mg/kgIndeno(1,2,3-cd)pyrene 0 0.0056 54 mg/kgLead 1.25 0.216 1,000 mg/kgNaphthalene 0 0.0056 43 mg/kgo-Xylene 0 0.0326 n/a mg/kgPhenanthrene 0 0.0056 n/a mg/kgPyrene 0 0.0056 1,500 mg/kgResidual Range Organics 17.3J 22.2 10,000 mg/kgToluene 0 0.0653 54 mg/kgTotal Xylene 0 0.0979 78 mg/kgXylene, Isomers m & p 0 0.0653 n/a mg/kg

SP20-CB-006 1-Methylnaphthalene 0 0.0055 n/a mg/kg2-Methylnaphthalene 0 0.0055 n/a mg/kgAcenaphthene 0 0.0055 210 mg/kgAcenaphthylene 0 0.0055 n/a mg/kgAnthracene 0 0.0055 4,300 mg/kgBenzene 0 0.0113 0.5 mg/kgBenzo(a)anthracene 0 0.0055 6 mg/kgBenzo(a)pyrene 0 0.0055 3 mg/kgBenzo(b)fluoranthene 0 0.0055 20 mg/kgBenzo(g,h,i)perylene 0 0.0055 n/a mg/kgBenzo(k)fluoranthene 0 0.0055 200 mg/kgChrysene 0 0.0055 620 mg/kgDibenzo(a,h)anthracene 0 0.0055 6 mg/kgDiesel Range Organics 0 22 2,500 mg/kgEthylbenzene 0 0.0218 5.5 mg/kgFluoranthene 0 0.0055 2,100 mg/kgFluorene 0 0.0055 270 mg/kgGasoline Range Organics 0 2.18 1,400 mg/kgIndeno(1,2,3-cd)pyrene 0 0.0055 54 mg/kgLead 0.712 0.223 1,000 mg/kgNaphthalene 0 0.0055 43 mg/kgo-Xylene 0 0.0218 n/a mg/kgPhenanthrene 0 0.0055 n/a mg/kgPyrene 0 0.0055 1,500 mg/kgResidual Range Organics 10.6J 22 10,000 mg/kgToluene 0 0.0436 54 mg/kgTotal Xylene 0 0.0654 78 mg/kgXylene, Isomers m & p 0 0.0436 n/a mg/kg

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TABLE 6BACKFILL CHARACTERIZATION SAMPLE RESULTS



Cleanup level UnitsSP20-CB-007 1-Methylnaphthalene 0.0029J 0.0057 n/a mg/kg

2-Methylnaphthalene 0.0041J 0.0057 n/a mg/kgAcenaphthene 0 0.0057 210 mg/kgAcenaphthylene 0 0.0057 n/a mg/kgAnthracene 0 0.0057 4,300 mg/kgBenzene 0 0.0153 0.5 mg/kgBenzo(a)anthracene 0 0.0057 6 mg/kgBenzo(a)pyrene 0 0.0057 3 mg/kgBenzo(b)fluoranthene 0 0.0057 20 mg/kgBenzo(g,h,i)perylene 0 0.0057 n/a mg/kgBenzo(k)fluoranthene 0 0.0057 200 mg/kgChrysene 0 0.0057 620 mg/kgDibenzo(a,h)anthracene 0 0.0057 6 mg/kgDiesel Range Organics 2.68J 22.4 2,500 mg/kgEthylbenzene 0 0.0293 5.5 mg/kgFluoranthene 0 0.0057 2,100 mg/kgFluorene 0 0.0057 270 mg/kgGasoline Range Organics 0 2.93 1,400 mg/kgIndeno(1,2,3-cd)pyrene 0 0.0057 54 mg/kgLead 1.06 0.222 1,000 mg/kgNaphthalene 0.0042J 0.0057 43 mg/kgo-Xylene 0 0.0293 n/a mg/kgPhenanthrene 0 0.0057 n/a mg/kgPyrene 0 0.0057 1,500 mg/kgResidual Range Organics 13J 22.4 10,000 mg/kgToluene 0 0.0587 54 mg/kgTotal Xylene 0 0.088 78 mg/kgXylene, Isomers m & p 0 0.0587 n/a mg/kg

Bold numbers indicate greater than ADEC cleanup levels.J = Estimated value due to value less than PQLB = EPA Flag - Analyte present in the blank and the sampleCL = Initial analysis within holding time but required dilutionGRO = Gasoline Range OrganicsDRO = Diesel Range OrganicsRRO = Residual Range Organicsmg/Kg = Milligrams per KilogramPQL = Practical Quantitation Limit

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